IRS PLR: Subsidiary Treated as Filing Form 1122 for Consolidated Return Purposes (IRC §1502)

The IRS has issued a private letter ruling on I.R.C. §1502-75(b)(2), concluding that the taxpayer shall be treated as if it had filed a Form 1122 for the relevant taxable year, allowing the Parent Affiliated Group to be treated as satisfying the requirements for filing a consolidated return. The taxpayer must file an amended return for each open year, check the “consolidated return” box, and attach Form 851 (Affiliations Schedule) as necessary. [PLR 202548030]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.