Ezel / IRS Rulings / 201022018

CCA 201022018: The applicable consolidated-return citation is Treas. Reg. § 1.1502-77

Number
201022018
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 corrects the regulation citation for the years at issue in a consolidated-return matter involving a parent acting for subsidiaries. It states that the correct citation is Treas. Reg. § 1.1502-77, rather than § 1.1502-77A, which applied to prior years. The advice is limited to identifying the applicable regulation for the years under review.

Ruling snapshot

  • Question: Which consolidated-return regulation applied to the years at issue?
  • Outcome: Advice given
  • Key authorities: Treas. Reg. §§ 1.1502-77 and 1.1502-77A

Full text (IRS public release)

ID: CCA_2010042813571237 Number: 201022018
Release Date: 6/4/2010
Office: ----------
UILC: 1502.77-00

From: -------------------
Sent: Wednesday, April 28, 2010 1:57:14 PM
To: --------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------
Subject: RE: 872-F for subs years -----------------------

The correct cite for the years in issue is 1.1502-77, not 77A which applied to prior years.

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