Acquisition of an S Corporation by a Member of a Consolidated Group

Samenvatting

This document contains proposed regulations under section 1502. The proposed regulations provide specific rules that apply to the acquisition of the stock of an S corporation by an affiliated group of corporations that joins in the filing of a consolidated return. These rules eliminate the compliance burdens associated with filing a separate return for the day that an S corporation is acquired by a consolidated group. Additionally, the proposed regulations clarify that Sec. 1.1502-76(c) continues to provide rules for the filing of the separate return for a corporation's items for the period not included in the consolidated return. This document also provides notice of a public hearing on these proposed regulations.