IRS PLR: Subsidiaries of Parent Taxpayer Treated as Having Joined in Affiliated Group Consolidated Return (IRC §1502)

The IRS has published a private letter ruling on Section 1502 and Treasury Regulation Section 1.1502 determining for the taxpayer, a C corporation and sole shareholder controlling subsidiaries 1, 2 and 3, each subsidiary a C corporation, that Treasury Regulation Section 1.1502-75(b)(2) can be applied to treat each subsidiary as if they had each filed Form 1122 and joined in the making of a consolidated return by the affiliated group. [PLR 202435016]

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