Document Number
84-153
Tax Type
Corporation Income Tax
Description
Conditions for filing a consolidated return
Topic
Returns/Payments/Records
Date Issued
09-18-1984

September 18, 1984


Re: Virginia Code § 58-151.079
    • Permission to File a Consolidated Return

Dear ******

The lead corporation has applied for permission to file a consolidated Virginia return with its wholly owned Virginia affiliates for the taxable year ending March 31, 1984 and years thereafter. Only one member of the affiliated group has filed Virginia returns in prior taxable years. This is the first year in which the lead corporation and the other three members of the affiliated group became liable for Virginia income tax. All members of the affiliated group use the same taxable year and apportion income using the three-factor formula.

Since this is the first year that two or more members of this affiliated group are liable for Virginia income tax, permission is hereby granted for the lead corporation and its Virginia affiliates to file a consolidated Virginia return for the taxable year ending March 31, 1984 and thereafter upon the following conditions:
    • 1. A copy of the federal consolidated return, or the separate federal return of each corporation included in the consolidated Virginia return, must be filed with the Virginia return. All supplementary and supporting schedules filed with a consolidated Virginia return should be prepared in columnar form, one column being provided for each corporation included in the consolidation, one column for a total of like items before adjustments are made, one column for intercompany eliminations and adjustments, and one column for a total of like items after giving effect to the eliminations and adjustments. The items included in the columns for eliminations and adjustments should be symbolized so as readily to identify contra items affected, and suitable explanations appended, if necessary.
    • 2. Once a consolidated return has been filed all subsequent returns by such corporations, their successors, and other members of the affiliated group who are subsequently required to file a Virginia income tax return, must also be filed on a consolidated basis unless the Department grants permission to change from a consolidated return.

Sincerely,




W. H. Forst
State Tax Commissioner

Rulings of the Tax Commissioner

Last Updated 08/25/2014 16:46