Annual information statement for
certain information about the reportable
corporation has a P.O. box, show the box
elections under section 108(i). If the
transaction by filing Form 8918, Material
number instead.
corporation made an election in 2009 or
Advisor Disclosure Statement, with the
Note. Do not use the address of the
2010 to defer income from cancellation of
IRS. See the Instructions for Form 8918.
registered agent for the state in which the
debt (COD) in connection with the
Transfers to a corporation controlled
corporation is incorporated. For example,
reacquisition of an applicable debt
by the transferor. Every significant
if a business is incorporated in Delaware
instrument, the corporation must attach a
transferor (as defined in Regulations
or Nevada and the corporation’s principal
statement to its return beginning with the
section 1.351-3(d)) that receives stock of
office is located in Little Rock, AR, the
tax year following the tax year for which
a corporation in exchange for property in
corporation should enter the Little Rock
the corporation made the election, and
a nonrecognition event must include the
address.
ending the first tax year all income
statement required by Regulations
deferred has been included in income.
If the corporation receives its mail in
section 1.351-3(a) on or with the
The statement must be labeled “Section
care of a third party (such as an
transferor’s tax return for the tax year of
108(i) Information Statement” and must
accountant or an attorney), enter on the
the exchange. The transferee corporation
clearly identify, for each applicable debt
street address line “C/O” followed by the
must include the statement required by
instrument to which an election under
third party’s name and street address or
Regulations section 1.351-3(b) on or with
section 108(i) applies, any deferred:
P.O. box.
its return for the tax year of the exchange,
•
COD income that is included in income
unless all the required information is
Item A. Identifying
in the current tax year.
included in any statement(s) provided by
•
COD income that has been accelerated
a significant transferor that is attached to
Information
because of an event described in section
the same return for the same section 351
108(i)(5)(D) and must be included in
exchange. If the transferor or transferee
Consolidated Return
income in the current tax year. Include a
corporation is a controlled foreign
description and the date of the
If an affiliated group of corporations
corporation, each U.S. shareholder
acceleration event.
includes one or more domestic life
(within the meaning of section 951(b))
•
COD income that has not been
insurance companies taxed under section
must include the required statement on or
included in income in the current or prior
801, the common parent may elect to
with its return.
tax years.
treat those companies as includible
Distributions under section 355. Every
•
OID deduction allowed as a deduction
corporations. The life insurance
corporation that makes a distribution of
in the current tax year.
companies must have been members of
•
stock or securities of a controlled
OID deduction that is allowed as a
the group for the 5 tax years immediately
corporation, as described in section 355
deduction in the current tax year because
preceding the tax year for which the
(or so much of section 356 as it relates to
of an accelerated event described in
election is made. See section 1504(c)(2)
section 355), must include the statement
section 108(i)(5)(D).
and Regulations section
•
required by Regulations section 1.355-5
OID deduction that has not been
1.1502-47(d)(12).
on or with its return for the year of the
deducted in the current or prior tax years.
Corporations filing a consolidated
distribution. If the distributing corporation
In addition, include a copy of the
return must check box 1 of Item A and
is a controlled foreign corporation, each
election statement the corporation filed to
attach Form 851, Affiliations Schedule,
U.S. shareholder (within the meaning of
make the election to defer the income.
and other supporting statements to the
section 951(b)), must include the
For more information regarding the
return. Also, for the first year a subsidiary
statement on or with its return.
annual information statement, see Rev.
corporation is being included in a
Dual consolidated losses. If a
Proc. 2009-37, 2009-36 I.R.B. 309.
consolidated return, attach Form 1122,
domestic corporation incurs a dual
Authorization and Consent of Subsidiary
consolidated loss (as defined in
Other forms and statements. See Pub.
Corporation To Be Included in a
Regulations section 1.1503-2(c)(5)), the
542, Corporations, for a list of other forms
Consolidated Income Tax Return, to the
corporation (or consolidated group) may
and statements a corporation may need
parent’s consolidated return. Attach a
need to attach an elective relief
to file in addition to the forms and
separate Form 1122 for each new
agreement and/or an annual certification
statements discussed throughout these
subsidiary being included in the
as provided in Regulations section
instructions.
consolidated return.
1.1503-2(g)(2).
File supporting statements for each
Election to reduce basis under section
corporation included in the consolidated
Specific Instructions
362(e)(2)(C). The transferor may make
return. Do not use Form 1120-PC as a
an election under section 362(e)(2)(C) to
substitute for the supporting statement.
limit the transferor’s basis in the stock
Period Covered
On the supporting statement, use
received instead of the transferor’s basis
columns to show the following, both
in the transferred property. The transferor
Generally, file the 2011 return for
before and after adjustments.
can make the election by including the
calendar year 2011. However, if an
1. Items of gross income and
certification as provided in Notice
insurance company joins in the filing of a
deductions.
2005-70, 2005-2, C.B. 694 on or with its
consolidated return, it may adopt the tax
2. A computation of taxable income.
tax return filed by the due date (including
year of the common parent corporation
3. Balance sheets as of the beginning
extensions) for the tax year in which the
even if that year is not a calendar year.
and end of the tax year.
transaction occurred. If the transferor is a
For a fiscal or short tax year return, fill in
4. A reconciliation of income per
controlled foreign corporation, its
the tax year space at the top of the form.
books with income per return.
controlling U.S. shareholder(s) can make
5. A reconciliation of retained
the election. The common parent of a
Name and Address
earnings.
consolidated group can make the election
Enter the corporation’s true name (as set
for the group.
forth in the charter or other legal
Enter on Form 1120-PC the totals for
If the election is made as described
document creating it), address, and EIN
each item of income, gain, loss, expense,
above, no election need be made by the
on the appropriate lines. Enter the
or deduction, net of eliminating entries for
transferee (or any controlling U.S.
address of the corporation’s principal
intercompany transactions between
shareholder thereof).
office or place of business. Include the
corporations within the consolidated
Once made, the election is irrevocable.
suite, room, or other unit number after the
group. Attach consolidated balance
See section 362(e)(2)(C) and Notice
street address. If the post office does not
sheets and a reconciliation of
2005-70.
deliver mail to the street address and the
consolidated retained earnings.
-5-
Instructions for Form 1120-PC (2011)