Ezel / IRS Rulings / 200912024

CCA 200912024: Chief Counsel specified signatures for consolidated-group partnership matters

Number
200912024
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Regulations Governing Consolidated Returns (May v. May Not File Consolidated Returns)
Topics
Corporate transactions and reorganizations
Code sections
§ 1502
Ruling dated
February 24, 2009
Publicly released
March 20, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advised how members of a consolidated corporate group should sign documents for partnership matters in two redacted years. For one year, the parent would sign for itself and the entire consolidated group, and a disregarded LLC through which it held the partnership interest would not sign separately. For the other year, both a subsidiary and the parent would sign, with the parent acting for itself and its subsidiaries, including that subsidiary. The advice provides the precise capacity language to use for each signature.

Ruling snapshot

  • Question: How should a consolidated corporate group sign documents concerning partnership matters for the redacted years?
  • Outcome: Advice given: the parent should sign for the group in one year, while the subsidiary and parent should both sign in the other year.
  • Key authorities: Consolidated-return rules under IRC § 1502.

Full text (IRS public release)

ID: CCA_2009022408503637 Number: 200912024
Release Date: 3/20/2009
Office: --------------
UILC: 1502.00-00

From: -------------------
Sent: Tuesday, February 24, 2009 8:50:38 AM
To: ----------------------
Cc: ------------------------------------
Subject: RE: TEFRA Questions ---------

For the ------- year the parent will sign for itself and the entire consolidated corporate filing group: "P, by
[current officer] for itself and subsidiaries." The LLC through which it owns its partnership interest is
disregarded for this purpose.

For--------: Signature 1: "S1, by [current officer of S1], [title of current officer of S1]," Signature 2: P,
by [current officer of P], [title of current officer of P], on behalf of itself and its subsidiaries, including S1".

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