Tax Type
Corporation Income Tax
Description
Combined return, New affiliates
Topic
Returns and Payments
Date Issued
05-23-2000
May 23, 2000
Re: Request for Ruling: Corporate Income Tax
Dear ****
This will respond to your letter in which you request permission for a new affiliate to be included in the combined return of ***** (the ``Taxpayer').
FACTS
The Taxpayer and a number of its affiliates requested permission in a prior year to file a Virginia combined return. Permission was granted and a Virginia combined return has been filed for a number of years. During 1998, the Taxpayer acquired a new affiliate and requests that it be allowed to include this affiliate in its Virginia combined return.
RULING
The Taxpayer has previously filed on the combined basis, thereby electing a combined filing status for all subsequent years. Because an election to file on a combined basis was made by the Taxpayer, any new affiliates that become subject to the Virginia corporate income tax are required to join in the Taxpayer's combined return pursuant to Title 23 of the Virginia Administrative Code (VAC) 10-120-323, copy enclosed.
If you have any questions regarding this ruling, please contact ***** of the Office of Tax Policy at *****
Sincerely,
Danny M. Payne
Tax Commissioner
OTP/25442P
Re: Request for Ruling: Corporate Income Tax
Dear ****
This will respond to your letter in which you request permission for a new affiliate to be included in the combined return of ***** (the ``Taxpayer').
FACTS
The Taxpayer and a number of its affiliates requested permission in a prior year to file a Virginia combined return. Permission was granted and a Virginia combined return has been filed for a number of years. During 1998, the Taxpayer acquired a new affiliate and requests that it be allowed to include this affiliate in its Virginia combined return.
RULING
The Taxpayer has previously filed on the combined basis, thereby electing a combined filing status for all subsequent years. Because an election to file on a combined basis was made by the Taxpayer, any new affiliates that become subject to the Virginia corporate income tax are required to join in the Taxpayer's combined return pursuant to Title 23 of the Virginia Administrative Code (VAC) 10-120-323, copy enclosed.
If you have any questions regarding this ruling, please contact ***** of the Office of Tax Policy at *****
Sincerely,
Danny M. Payne
Tax Commissioner
OTP/25442P
Rulings of the Tax Commissioner