Ezel / IRS Rulings / 200943030

CCA 200943030: LMSB managers may designate a consolidated-group substitute agent

Number
200943030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Common Parent Agent for Subsidiaries
Topics
Corporate transactions and reorganizations
Code sections
§ 1502
Ruling dated
June 26, 2009
Publicly released
October 23, 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

This Chief Counsel Advice addresses the designation of a substitute agent for a consolidated group. It states that Delegation Order 4-45 authorizes Team Managers in LMSB, as to their respective cases, to make the designation. The advice says no form is required. Instead, the corporation may be sent a letter stating that it is being designated under Treas. Reg. § 1.1502-77(d)(3) and advising it to notify the other corporations that were group members for the years at issue.

Ruling snapshot

  • Question: How may an authorized LMSB Team Manager designate a substitute agent for a consolidated group?
  • Outcome: Advice given
  • Key authorities: IRC § 1502; Treas. Reg. § 1.1502-77(d)(3); Delegation Order 4-45

Full text (IRS public release)

ID: CCA-626135-09 Number: 200943030
Release Date: 10/23/2009
Office: --------------------
UILC: 1502.77-00

From: ---------------------
Sent: Fri 6/26/2009 1:48 PM
To: ---------------------
Cc:
Subject: Designation by Commissioner

------------

Delegation Order 4-45 provides that Team Managers in LMSB are authorized ("as to their respective cases") to designate a substitute agent for a consolidated group.

As we discussed, there is no form. It's sufficient to send a letter to the corporation advising that it's being designated as the substitute agent pursuant to sec. 1.1502-77(d)(3) and also advising it to notify the other corporations that were members for the year(s) at issue.

Please let me know if you have any questions.

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