Tax News

CCH (cch.taxgroup.com) reports:

The IRS has issued a final regulation that gives the IRS the authority to designate a domestic member of a consolidated group as a substitute agent for the group where a foreign entity is the group's common parent. A domestic member of the consolidated group that is designated the substitute agent will continue to be the group's agent until its existence terminates. Under the new regulation, if a group with a domestic substitute agent continues in existence with a new common parent that is a domestic corporation during a consolidated return year, the substitute agent is the agent of the group for the year until the new common parent becomes the comment parent. After that time, the new common parent becomes the agent of the group. The new rules are effective as of July 23, 2007.
T.D. 9343, 2007FED ¶47,050
Other References:
Code Sec. 1502
CCH Reference - 2007FED ¶33,168.0232
Tax Research Consultant
CCH Reference - TRC CCORP: 45,152
CCH Reference - TRC CCORP: 45,154
CCH Reference - TRC CONSOL: 9,204.10