Classify each of the following is an Advantage or a Disadvantage of filing consolidated returns. The local
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Classify each of the following is an "Advantage" or a "Disadvantage" of filing consolidated returns.
The local CPA Society is presenting its annual tax conference. Most of the attendees will be career tax professionals who work with smaller clients. You have been asked to submit an outline for your talk, "When to Use a Consolidated Tax Return: Federal Tax Law Issues."
In preparing for your talk,
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a. Use of operating and capital loss carryovers of one group member to shelter the corresponding income of other group members. Elimination of taxes on intercompany dividends. Binding nature of the election on the group members for all subsequent tax years, unless the makeup of the affiliated group changes or the IRS consents to revocation of the election. b. C. d. Application of the capital and operating losses of one group member against the corresponding income of the other group members, even when assigning the losses to separate return years would produce a greater tax benefit. Deferred recognition of income from certain intercompany transactions. f. Decreased amounts of certain deductions and credits when consolidated amounts are used in computing pertinent limitations. Increased administrative costs from compliance with the consolidated return regulations. e. g. h. Optimization of certain deductions and credits through the use of consolidated amounts in computing pertinent limitations. i. j. k. I. m. Advantage Creation of short taxable years of subsidiaries, thereby bunching together income, and one of the years of the subsidiary's charitable contribution and loss carryforward period may be lost. Recognition of legal and other rights of minority shareholders in the context of a consolidated group. Advantage Disadvantage Disadvantage Advantage Disadvantage Disadvantage Advantage Use of current-year operating losses of one group member to defer or reduce the estimated tax payments of the entire group. Deferred recognition of losses from certain intercompany transactions. Advantage Increased tax basis of investments in the stock of subsidiaries because of positive subsidiary taxable Disadvantage income. Advantage Disadvantage Disadvantage a. Use of operating and capital loss carryovers of one group member to shelter the corresponding income of other group members. Elimination of taxes on intercompany dividends. Binding nature of the election on the group members for all subsequent tax years, unless the makeup of the affiliated group changes or the IRS consents to revocation of the election. b. C. d. Application of the capital and operating losses of one group member against the corresponding income of the other group members, even when assigning the losses to separate return years would produce a greater tax benefit. Deferred recognition of income from certain intercompany transactions. f. Decreased amounts of certain deductions and credits when consolidated amounts are used in computing pertinent limitations. Increased administrative costs from compliance with the consolidated return regulations. e. g. h. Optimization of certain deductions and credits through the use of consolidated amounts in computing pertinent limitations. i. j. k. I. m. Advantage Creation of short taxable years of subsidiaries, thereby bunching together income, and one of the years of the subsidiary's charitable contribution and loss carryforward period may be lost. Recognition of legal and other rights of minority shareholders in the context of a consolidated group. Advantage Disadvantage Disadvantage Advantage Disadvantage Disadvantage Advantage Use of current-year operating losses of one group member to defer or reduce the estimated tax payments of the entire group. Deferred recognition of losses from certain intercompany transactions. Advantage Increased tax basis of investments in the stock of subsidiaries because of positive subsidiary taxable Disadvantage income. Advantage Disadvantage Disadvantage
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