Ezel / IRS Rulings / 201022017

CCA 201022017: The parent may sign for the entire consolidated group

Number
201022017
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Common Parent Agent for Subsidiaries
Topics
Corporate transactions and reorganizations
Code sections
§ 1502
Ruling dated
April 28, 2010
Publicly released
June 4, 2010
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 2010, 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 2010
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 Advice states that the parent may sign for the entire consolidated group in the matter described in the email. The advice cites Treas. Reg. § 1.1502-77A and includes redacted details about the subsidiaries and the specific filing. The short CCA addresses who may sign on behalf of the consolidated group.

Ruling snapshot

  • Question: May the parent sign for the entire consolidated group?
  • Outcome: Advice given
  • Key authorities: Treas. Reg. § 1.1502-77A

Full text (IRS public release)

ID: CCA_2010042813324237 Number: 201022017
Release Date: 6/4/2010
Office: ----------
UILC: 1502.77-00

From: -------------------
Sent: Wednesday, April 28, 2010 1:32:48 PM
To: --------------------
Cc: ------------------------------------
Subject: RE: 872-F for subs years -------------

The parent can sign for the entire consolidated group, --------------------------------------------------------------------
----------------------------------------. Treas. Reg. 1.1502-77A.

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