Black, Brown, and Red Corporations are considering a corporate restructuring that would allow them to file Federal income tax returns on a consolidated basis. Black holds significant NOL carryforwards from several years ago. Brown always has been profitable and is projected to remain so. Red has been successful, but its product cycles are mature and operating losses are likely to begin three years from now and last for a decade. What tax issues should the corporations consider before electing to file on a consolidated basis?