parent-subsidiary controlled group

(5) Definitions For purposes of this subsection— (A) Parent-subsidiary controlled group The term “parent-subsidiary controlled group” means any controlled group of corporations described in section 1563(a)(1). In determining the average adjusted bases of assets held by such a group, interests held by one member of such group in another member of such group shall be disregarded. (B) Disqualification year The term “disqualification year” means, with respect to any bank, the 1st taxable year beginning after December 31, 1986 , for which such bank was a large bank if such bank maintained a reserve for bad debts for the preceding taxable year. (C) Election made by each member In the case of a parent-subsidiary controlled group, any election under this section shall be made separately by each member of such group.

Source

26 USC § 585(c)(5)


Scoping language

None identified. Default scope is assumed to be the entire title.
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