Tax Type
Corporation Income Tax
Description
Permission to file a combined return
Topic
Returns/Payments/Records
Date Issued
12-14-1984
- December 14, 1984
Re: Virginia Code § 58-151.079-
- Permission to File a Combined Return
Dear ****
This is in response to your letter of August 17, 1984 requesting permission for the above referenced taxpayers to file a combined Virginia income tax return. The subsidiary corporations are all eligible affiliates subject to Virginia income tax. They all utilize the same taxable year and separate returns have been filed in prior years. The parent corporation is not subject to Virginia income tax.
Permission is hereby granted for the subsidiary corporations to file a combined return for the taxable year ending December 31, 1983 and thereafter. The combined return is to be filed under the name and federal identification number of the Designated Lead Affiliate and shall include all of the affiliates subject to Virginia income tax upon the following conditions:-
- 1. 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