- Imagine that a client is pursuing the acquisition of Corporation A that hasa substantial net operating loss. Corporation B is a member of the controlledgroup and is currently included in the consolidated tax return that also has anet operating loss. Analyze the potential advantages and disadvantages ofCorporation B’s acquisition of Corporation A and Corporation A’s subsequentinclusion in Corporation B’s consolidated tax return. Suggest the key tax issuesthe client should consider in determining the deductibility of the net operatinglosses.
- Imagine that corporations P, S, and C are members of a parent-subsidiarycontrolled group filing a consolidated tax return. Corporations A and B aremembers of a brother-sister controlled group that cannot file a consolidated taxreturn. Design a strategy geared toward creating an affiliated group which makesCorporations A, B, P, S, and C all eligible to file a consolidated tax return.
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