Tax Type
Corporation Income Tax
Description
Combined Return
Topic
Corporate Distributions and Adjustments
Date Issued
12-10-1982
December 10, 1982
Re: § 58-151.079; Permission to File a Combined Return
Dear **********************
The parent corporation has requested permission to file a combined Virginia return including itself and those subsidiaries doing business in Virginia,. The corporations have filed separate Virginia returns and a consolidated federal return in prior years. The parent has also requested permission to file amended returns on a combined basis for the taxable year beginning December 26, 1980 (the corporations use a 52/53 week fiscal year),, however the amendment allowing combined returns is effective only for taxable years beginning on or after January 1, 1981. Please note that under § 58-151.081 a combined return may not include a corporation which does not do business in Virginia.
Permission is hereby granted to file a combined return for taxable years beginning on or after January 1, 1981 which includes all affiliates doing business in Virginia 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 and every 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