Tax Type
Corporation Income Tax
Description
Permission to file a combined return
Topic
Returns/Payments/Records
Date Issued
11-30-1984
- November 30, 1984
Re: Virginia Code § 58-151.079 (on and after January 1, 1985 58.1-442)
Permission to File a Combined Return
Dear ****
This is in response to your letter of October 15, 1984 requesting permission for the above referenced taxpayers to file a combined Virginia income tax return. ***** from your office, indicated in a telephone conversation with a member of my staff on November 16, 1984, that the parent would also like permission to file combined amended returns for prior years. The corporations are eligible affiliates subject to Virginia income tax. All corporations utilize the same taxable year and separate returns have been filed in prior years.
Permission is hereby granted to file a combined return for the taxable year ending June 30, 1982 and thereafter which includes 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.
Please attach a copy of this letter to the amended returns, if you choose to file amended returns for the prior years.
Sincerely,
W. H. Forst
State Tax Commissioner
Rulings of the Tax Commissioner