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October 2018 » Consolidated Group Tax Allocation...
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Michele Frank, PhD, and Charles Lenns, JD
In BriefWhen several corporations are consolidated into one large group, the parent company deals directly with the IRS, paying the tax liabilities for the group and receiving any refunds. Tax allocation agreements are often used by the members of a consolidated group in order to determine how to allocate and distribute such funds. The authors detail the issues corporations need to consider when drafting such agreements, including how the carryback and carryforward of net operating losses have been affected by the Tax Cuts and Jobs Act of 2017.
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