IRS T.D.: Final Regulations on Single-Entity Treatment of Consolidated Groups Owning Foreign Corporations (IRC §1502)

Final regulations issued to treat consolidated group members as a single U.S. shareholder in certain cases for purposes of I.R.C. §951(a)(2)(B), affecting consolidated groups that own stock of foreign corporations. The proposed regulations were adopted without modification. The final rules are effective on Feb. 23, 2023, and apply to tax years for which the original consolidated return is due (without extensions) after Feb. 23, 2023. [T.D. 9973, RIN 1545-BQ51, 88 Fed. Reg. __ (Feb. 23, 2023)]

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