Regulations Governing Intercompany Transactions Within Consolidated Groups

Extract

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Regulations Governing Intercompany Transactions Within Consolidated Groups

Originally published October, 2003

1. INTRODUCTION

TABLE OF CONTENTS

I. INTRODUCTION

A. In General

B. Summary of the Current Intercompany Transaction Rules

C. Summary of the Old Intercompany Transaction Rules

II. DEFINITIONS

A. Denomination of Selling and Buying Member

B. Definition of an Intercompany Transaction

C. Intercompany Items and Corresponding Items

D. Timing Rules As a Method of Accounting

III. THE MATCHING RULE

A. In General

B. Timing under the Matching Rule

C. Holding Period Aggregation

D. Redetermination of Other Attributes

E. Conflict or Allocation of Attributes

F. Special Status

G. Limitation on exclusion of intercompany gain

H. Additional Examples Illustrating the Matching Rule

IV. THE ACCELERATION RULE

A. General Rule

B. Application of the Acceleration Rule to S's Items

C. Application of the Acceleration Rule to B's Items

D. Exception for Acquisition of Entire Group

E. Acceleration Rule Examples

V. SIMPLIFYING EXCEPTIONS

A. Dollar-Value LIFO Inventory Methods

B. Reserve Accounting and Similar Items

C. Consent to Treat Intercompany Transactions on a Separate Entity Basis

VI. SPECIAL RULES FOR MEMBER STOCK

A. § 301 Distributions

B. Boot in Intercompany Reorganizations

C. Acquisition by Issuer of its Own Stock

D. Relief for Certain Liquidations and Distributions

E. Transactions Involving Common Parent

VII. SPECIAL RULES F...

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