Treasury regulation Sec. 1.1503-2(b)
provides that a dual consolidated loss of a dual resident
corporation cannot offset the taxable income of any domestic
affiliate in the taxable year in which the loss is recognized or in
any other taxable year. To implement this general rule and its
exceptions, Treas. Reg. Subsection 1.1503-2, 1.1503-2A, and
1.1503-2T require various filings to be included in a timely filed
tax return. Taxpayers that fail to include Sec. 1503(d) filings on
a timely basis are currently required to request an extension of
time to file under the provisions of Sec. 301.9100-1 through
301.9100-3.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.