Affiliated Group

Affiliated Group

A set of companies owned by the same parent company. An affiliated group often files its tax returns as if it were a single company, but this is not always the case. See also: Affiliated Corporation.
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408, the IRS announced its intention to modify the section 861 regulations essentially to eliminate the word "generally," thereby requiring taxpayers to ratably apportion the deduction for charitable contributions to all classes of gross income on an affiliated group basis.
affiliated group of corporations generally must allocate interest expense based on the relative value of foreign and U.
Hilb Rogal & Hobbs Company (NYSE: HRH), the world's 10th largest insurance and risk management intermediary, announced today that it has signed a definitive agreement to acquire substantially all of the operating assets of the The Federau Group, an affiliated group of insurance agencies located in Lansing, Michigan.
The modification allows rents and royalties to be treated as active if the relevant requirements are satisfied by any member of the corporation's affiliated group (defined by including only U.
The rules governing the filing of consolidated tax returns by affiliated groups currently supply guidance on (1) the application of estimated tax payments by individual members for the group's consolidated tax liability, (2) joint and several liability of members for the group's tax liability, (3) the application of loss and credit carrybacks to, and carryovers from, separate return years, and (4) other administrative issues affecting the determination and allocation of tax liability of an affiliated group filing a consolidated return.
Under those rules, interest expense incurred by one member of an affiliated group can be allocated to the foreign source income of another member.
Under this approach, an affiliated group is treated as a single taxpayer; interest expense is apportioned on the basis of all group members; see Temp.
30) Where the acquired corporation is the parent of an affiliated group, a mini-tax basis study may be necessary to ascertain the initial basis in the stock of the corporation acquired as well as the basis of each of the lower-tier subsidiaries.
Its affiliated group of companies is one of the nation's largest providers of student loan services.
In an affiliated group, this typically occurs when one corporation borrows funds from a third party, then transfers the funds to a related affiliate that invests them in exempt obligations.
1502-13(f)(5)(i) states that, in an affiliated group consisting of, parent, P, and first-tier subsidiaries, S and B, and S's subsidiary, T, "S's intercompany items from an intercompany transfer to B of the stock of .
However, such designations may be assigned when the insurer's financial strength rating is constrained by sovereign risk or the credit quality of a parent company or affiliated group.
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