Tax Type
Corporation Income Tax
Description
Permission to file a combined return
Topic
Returns/Payments/Records
Date Issued
07-31-1984
July 31, 1984
Re: Virginia Code § 58-151.079
Permission to File Combined Return
Dear *******
This is in response to your letter of June 15, 1984 requesting permission for the above referenced taxpayers to file a combined Virginia income tax return. The corporations are eligible affiliates subject to Virginia income tax and all corporations utilize the same taxable year. The corporations are currently filing on a consolidated basis for federal purposes. The parent corporation and three of the subsidiaries have filed a consolidated Virginia return in prior years, since they are all 100% Virginia corporations. The fourth subsidiary ***** which became eligible to be included in the consolidated federal return on January 3, 1983, is a multistate corporation.
Permission is hereby granted to file a combined return for the taxable year ending December 31, 1983 and thereafter which includes the affiliates subject to Virginia income tax upon the following conditions:
l. Schedules shall be filed with the combined return which contain all information which would be contained in a separate Virginia return for each eligible member of the affiliated group. See §§ 58-151.079 and 58-151.081.
2. In computing the Virginia taxable income of each eligible member of the affiliated group there shall be added to federal taxable income the amount of any net operating loss deduction or other deduction which has been recognized for Virginia income tax purposes and offset other income in a Virginia consolidated or combined return for other taxable years. See, for example, Federal Income Tax Regulation 1.1502-79.
Sincerely,
W. H. Forst
State Tax Commissioner
Rulings of the Tax Commissioner