Page 645 - Large Business IRS Training Guides
P. 645
Consolidated Groups
1
• Final
regulations generally adopt a “single US entity”
consolidated groups, with important nuances:
approach for
• The consolidated group aggregates the pro rata shares
tested loss, and specified interest expense of
of QBAI,
each consolidated group member.
• A portion of each consolidated CFC tested item is
allocated back to each member
based on the member’s
which equals the ratio of the
GILTI allocation ratio,
member’s aggregate pro rata share of tested income to
consolidated tested income.
Treas. Reg.
§1.1502-51(b).
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