Discussion ACC565 11/2/21
When a group of corporations comes together to form an affiliated group for tax purposes, individual corporate members in the group may choose to file their own income tax return or file a group tax return; with an agreement of all the group members, they can elect to file a consolidated return. Imagine that a client is pursuing the acquisition of Corporation A that has a substantial net operating loss. Corporation B is a member of a controlled group and is currently included in a consolidated tax return that also has a net operating loss.
Analyze the potential advantages and disadvantages of Corporation B’s acquisition of Corporation A and Corporation A’s subsequent inclusion in Corporation B’s consolidated tax return.
Suggest the critical tax issues the client should consider in determining the deductibility of the net operating losses.
Evaluate the impact of the Tax Cuts and Jobs Act (TCJA) on the net operating losses.