Ezel / IRS Rulings / 201112012

CCA 201112012: Four corporations may form a combined group

Number
201112012
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions and Special Rules
Topics
Corporate transactions and reorganizations
Code sections
§ 1563, § 6110
Ruling dated
January 21, 2010
Publicly released
March 25, 2011
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 2011, 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 2011
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 that Corporations A, B, C, and D could be treated as a combined group under section 1563(a)(3), after applying sections 1563(a)(1) and (a)(2). The advice also agreed that Corporation D and Corporation A were related under section 1563.

Ruling snapshot

  • Question: May the four corporations be treated as a combined group and may Corporations D and A be treated as related?
  • Outcome: Advice given.
  • Key authorities: IRC §§ 1563(a)(1), 1563(a)(2), and 1563(a)(3)

Full text (IRS public release)

ID: CCA-121256-10 Number: 201112012
Release Date: 3/25/2011
Office: --------------
UILC: 1563.00-00

From: ---------------------
Sent: Thursday, January 21, 2010 2:56 PM
To: -------------------
Cc: ---------------------
Subject: RE: question ---------

wow tough question ...

but I think we can say that Corps A, B, C and D are a "combined group" under
1563(a)(3) -- we get there after looking at 1563(a)(1) and (a)(2)

so I think I agree with you that Corp D and Corp A are related under 1563

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