Consolidated Return Fundamentals in C Corporations

Summary

This practice note offers a general overview of the U.S. federal consolidated income tax return (consolidated return) rules, which are primarily found in the Treasury Regulations promulgated under I.R.C. Section 1502. In general, only a domestic or U.S. C corporation (including an LLC classified as a corporation) can be a member of a consolidated group, I.R.C. § 1504(a)(1)(A), (b), and all references to "corporation" or "company" in this note refer to domestic C corporations unless specifically indicated otherwise. This practice note will also discuss filing the initial consolidated return, estimated consolidated tax payments, affiliation, and other schedules intercompany transactions.