Consolidated Net Operating Losses and Intercompany

Due by 8/2/2014 by midnight.  Each discussion question should be at least one page long with references.
Week 5 E- activity
•	Go to the Tax Almanac Website, located here, or use the Internet and Strayer databases to research the Section 267(f) of the IRC; Deferral of loss on transactions between members of a controlled group. Focus on losses between members of a controlled group. Be prepared to discuss

Week 5 Discussion 1
"Consolidated Net Operating Losses and Intercompany Transactions" Please respond to the following:
•	A client is pursuing the acquisition of Corporation A that has a substantial net operating loss. Corporation B is a member of the controlled group and is currently included in the consolidated tax return that also has a net operating loss. Analyze the potential advantages and disadvantages of Corporation B- acquisition of Corporation A and Corporation A- subsequent inclusion in Corporation B- consolidated tax return. Suggest the key tax issues the client should consider in determining the deductibility of the net operating losses.
•	From the e-Activity, create a tax-planning strategy for a client geared toward complying with the final regulations issued by the IRS under Code Section 267 (f). (Note: Code Section 267 (f) discusses the time taken into account for deferred losses on the sale or exchange of property between members of a controlled group.) Recommend the alternatives that you believe would be best suited for the client to use in order to both take advantage of losses between members and remain in compliance with related regulations. Justify your response.
Week 5 Discussion 2
"Consolidated Tax Returns" Please respond to the following:
•	Corporations P, S, and C are members of a parent-subsidiary controlled group filing a consolidated tax return. Corporations A and B are members of a brother-sister controlled group that cannot file a consolidated tax return. Design a strategy geared toward creating an affiliated group which makes Corporations A, B, P, S, and C all eligible to file a consolidated tax return.
•	Assess the adequacy of the schedule M-3 Part 1 in creating transparency between the consolidated financial statements and the consolidated tax returns of the corporations discussed in the first part of this discussion. Suggest at least two (2) modifications to the M-3 that you can use to identify possible issues the IRS would most likely examine on a consolidated tax return