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IRS PLR: Consolidated Return for Preceding Year, Safe Harbor for Capital Expenditures Filing Extensions Granted (IRC §1502)

July 31, 2020, 5:00 AM

In two PLRs, an affiliated corporate group received extra time to file a consolidated federal income tax return for a preceding tax year, and one (PLR 202031005) additionally involved an annual election to apply the de minimis safe harbor for capital expenditures. In each case the reasons for not meeting the original due date are explained in submitted documentation. The relief is conditioned on the group’s tax liability (if any) being not lower, in the aggregate, for all years to which the election applies, than it would have been with a timely made election (taking into account the time value...

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