affiliated group
(4) Treatment of certain intragroup transactions (A) In general In the case of any transfer described in subsection (a) of stock from 1 member of an affiliated group to another member of such group, proper adjustments shall be made to— (i) the adjusted basis of any intragroup stock, and (ii) the earnings and profits of any member of such group, to the extent necessary to carry out the purposes of this section. (B) Definitions For purposes of this paragraph— (i) Affiliated group The term “affiliated group” has the meaning given such term by section 1504(a). (ii) Intragroup stock The term “intragroup stock” means any stock which— (I) is in a corporation which is a member of an affiliated group, and (II) is held by another member of such group.