Document FR Doc. 94-8488 Consolidated Groups and Controlled GroupsIntercompany Transactions and Related Rules

1994-04-15 · Treasury · IRS · Comments closed 1994-07-18

This document proposes regulations revising the intercompany transaction system of the consolidated return regulations to more clearly reflect consolidated taxable income. The proposed regulations also revise the regulations under section 267(f), limiting losses and deductions from comparable transactions between members of a controlled group. Amendments to other related regulations are also proposed in this document.