Instructions For Schedule O (Form 1120) - 2012
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9Instructions for Schedule O
Department of the Treasury
Internal Revenue Service
(Form 1120)
(Rev. December 2012)
Consent Plan and Apportionment Schedule for a Controlled Group
group, even if (1) no apportionment
adopting, amending, or terminating
Section references are to the Internal
Revenue Code unless otherwise noted.
plan is in effect, or (2) the amounts
the apportionment plan.
apportioned have not changed from
The agreement must be signed by
Future Developments
the previous tax year. See Definitions
a person authorized to sign on behalf
For the latest information about
and Special Rules, below.
of each component member of the
developments related to Schedule O
controlled group and retained. No
Consolidated groups. If any of the
(Form 1120) and its instructions, such
member should attach this agreement
component members of a controlled
as legislation enacted after they were
(or a copy of it) to their federal income
group are also members of a
published, go to
tax returns. Each component member
consolidated group, then the common
form1120.
must keep, as part of its records,
parent of that consolidated group
either the original or a copy of the
must file, as part of its consolidated
General Instructions
signed agreement. The agreement
income tax return, one Schedule O on
must contain the group's
behalf of the members of that
apportionment methodology (for
Purpose of Schedule
consolidated group. No subsidiary of
example, percentages) for each tax
that consolidated group should file
A corporation that is a component
benefit item that is apportioned.
Schedule O on its own behalf. The
member (defined below) of a
Schedule O should contain the
controlled group must use
Definitions and Special
required consolidated information for
Schedule O to report the
Rules
all members of the consolidated
apportionment of taxable income,
group. See Identifying Information.
income tax, and certain tax benefits
Types of Controlled Groups
between all component members of
Exception. If all of the members of
Parent-subsidiary group. A
the group. These members will be
a parent-subsidiary controlled group
parent-subsidiary group is one or
subject to limitations on the use of
that are required to file a U.S. tax
more chains of corporations
certain tax benefits for their applicable
return join in filing the same
connected through stock ownership
tax year. See Apportionment of Tax
consolidated tax return, then the
with a common parent corporation if:
Benefit Items.
parent of that group does not have to
Stock possessing at least 80% of
file Schedule O on behalf of the
Also use Schedule O to indicate
the total combined voting power of all
group.
that the member filing this return
classes of stock entitled to vote or at
consents to and represents that all the
Completing and Filing
least 80% of the total value of shares
other component members of the
of all classes of stock of each of the
Schedule O
controlled group:
corporations, except the common
In completing Schedule O, the
Are adopting an apportionment
parent corporation, is directly or
following apply.
plan, effective for the current tax year;
indirectly owned by one or more of the
The filing of Schedule O by a
Are amending the existing
other corporations; and
component member provides the
apportionment plan;
The common parent corporation
required information as to the status
Are terminating the existing
directly or indirectly owns stock
of the group's apportionment plan.
possessing at least 80% of the total
apportionment plan and not adopting
Such information must indicate, when
a new plan;
combined voting power of all classes
applicable, whether all the component
of stock entitled to vote or at least
Are terminating the existing
members of the controlled group are
80% of the total value of shares of all
apportionment plan and adopting a
adopting, amending, or terminating an
classes of stock of at least one of the
new plan;
apportionment plan.
other corporations, excluding, in
Have no apportionment plan in
If all such members complete the
computing such voting power or
effect and are not adopting an
required written agreement setting
value, stock owned directly by such
apportionment plan; or
forth the terms of the adopted or
other corporations.
Already have an apportionment
amended apportionment plan (or an
plan in effect.
For purposes of determining
agreement to terminate a previously
whether a corporation is a member of
adopted plan), then each member of
Who Must File
a parent-subsidiary controlled group
that group may rely on this agreement
of corporations within the meaning of
A corporation must file Schedule O
as the member's basis for
section 1563(a)(1), stock owned by a
with its income tax return, amended
representing on its Schedule O that
corporation means:
return, or claim for refund for each tax
the other component members of the
year that the corporation is a
Stock owned directly by the
group have also consented to
component member of a controlled
corporation, and
Nov 16, 2012
Cat. No. 48211V
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