IRS CCA: Parent Group’s Taxable Year Didn’t Terminate With New Common Parent Reorganization (IRC §1502)

The taxable year of an affiliated group of corporations didn’t terminate as a result of transactions that made “New Parent” the common parent but continued until the year closed on “Date 8,” the Chief Counsel’s Office advised in a memorandum containing redactions. New Parent, a foreign entity formed on “Date 1” by “Parent,” made an initial election to be treated as an entity disregarded as separate from its owner and, with “New Parent Formation,” effective “Date 6,” elected to be treated as an association for federal income tax purposes. [CCA 201933009]

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