Busting Consolidation – Example 1
{"Image DocumentName": "Busting Consolidation \u2013 Example 1", "Image ImageDescription": "FP. 100% P. 50% S. 50% LLC. X. Facts: FP, a foreign corporation, owns 100% of the stock of P, which owns all of the stock of S, which owns all of the stock of X. P, S, and X file a consolidated return. In order to deconsolidate X, S contributes the stock of X to an LLC formed by S and FP. Result: Because X is no longer an includible corporation, it should not be a member of P\u2019s consolidated group. Analysis: No business purpose and no profit potential.", "Image XResolution": "37", "Image YResolution": "37", "Image ResolutionUnit": "Pixels/Centimeter", "Image Software": "SlidePlayer", "Image YCbCrPositioning": "Centered"}