Document Number
86-87
Tax Type
Corporation Income Tax
Description
Permission to file a consolidated return
Topic
Returns/Payments/Records
Date Issued
04-29-1986
April 29, 1986


Re: Corporation Income Tax
§58.1-442 Permission to file a consolidated return

Dear ****************

The parent corporation has requested permission to file a consolidated Virginia return for itself and its subsidiaries for the taxable year beginning January 1, 1986. All of the companies use the same apportionment factor and have the same taxable year. The corporations currently file separate Virginia returns. The reason for request is that filing separate returns requires significant extra clerical time to prepare separate returns, extension requests, estimated payments and other items.
Determination

Virginia Regulation §630-3-442 E state:
    • 1. Permission to change to or from filing consolidated returns will generally not be granted. Such changes affect the allocation and apportionment factors and distort the business done in Virginia and the income arising from activity in Virginia.
      2. Separate and combined returns do not affect the allocation and apportionment formulas for each corporation and permission to change from separate returns will generally be granted
Therefore permission to file a consolidated Virginia return is denied. In a conversation with a member of my staff you indicated that a combined Virginia return would be acceptable. In a combined return only one extension request and one set of estimated payments is required. The return is filed on one form
with schedules attached showing the separate computation of income.

Accordingly, permission is granted to file a combined Virginia return for the taxable year 1986 and thereafter which includes the corporations listed above and any corporations which may become affiliated with the group in the future.

Sincerely,



W. H. Forst
Tax Commissioner

Rulings of the Tax Commissioner

Last Updated 08/25/2014 16:46