6651(a), as well as civil penalties if certain international information returns—such as Forms 5471, —are required to be attached to a timely filed return.When a target corporation becomes a member of a consolidated group and the target corporation has a short year that ends on the day the consolidated group acquires the corporation, Regs. 1.1502-76(c) provides the rules for determining the due date of the target's short-period return.
It also analyzes: (1) the administrative rules for electing and filing consolidated returns; (2) the eligibility requirements that must be met in order to file a consolidated return; and (3) the computation of estimated tax payments if consolidated returns are filed.
This Portfolio is one of four Portfolios devoted to an analysis of consolidated returns.
At the time of this writing, the IRS had just issued proposed regulations under Regs. 1.1502-76 that would amend paragraph (b)(4) to clarify that the short-period return due date for a target corporation that ceases to exist in the same consolidated-return year in which it becomes a member of a consolidated group is determined without regard to the target's ceasing to exist that year (REG-100400-14).
Under the short-period return due-date rules in Regs. 1.1502-76(c), the due date for the short-period return is determined based on the close of the target corporation's regular tax year as if the year had not ended early due to the acquisition.
Report a distribution received from a foreign trust; or, if the corporation was the grantor of, transferor of, or transferor to, a foreign trust that existed during the tax year. Use Form 4562 to claim a deduction for depreciation or amortization, to make the section 179 election to expense certain property, and to provide information on the business/investment use of cars and other listed property.