Consolidated and Controlled Groups- Intercompany Transactions and Related Rules

The Treasury regulations require common parents that make elections under Section 1.1502-13 to provide certain information. Section 1.1502 13(f)(5)(ii) provides common parents with an election to avoid potential duplications of gain from certain intercompany distributions and other transactions with respect to stock of members. These elections are designed to provide taxpayers relief from the application of certain provisions of the regulations. These elections must be made by the due date for the consolidated returns (including extensions). The section 1.1502 13(f)(5)(ii) election is made by attaching a statement to the consolidated return. Section 1.1502-13(f)(6)(i)(C) provides for an election to reduce basis in parent stock. The election must be made in a separate statement filed with the consolidated group's tax return. The information will be used to identify and assure that the amount, location, timing and attributes of intercompany transactions and corresponding items are properly maintained. Burden for the collection of information requirements under 1.1502 13(e)(3) and 1.1502 13(c) are being reported under OMB number 1545-0123.

The latest form for Consolidated and Controlled Groups- Intercompany Transactions and Related Rules expires 2020-11-30 and can be found here.