IRS PLR: Consolidated Return Filing Retroactive Relief Granted (IRC §1502)

Four wholly owned subsidiaries will be treated as having filed Form 1122, Authorization and Consent of Subsidiary To Be Included in a Consolidated Income Tax Return, for three tax years where the group didn’t satisfy the consolidated return filing requirements. While the group did not qualify for automatic relief under Revenue Procedure 2014-24, because Parent did not attach to its returns a Form 851, Affiliations Schedule, or reference the subsidiaries, and certain other conditions were not met, the IRS said relief under Treasury Regulations Section 1.1502-75(b)(2) could be applied with consideration to facts and circumstances, ...