- 12 - alternative minimum taxable income (as defined in paragraph (b)(3)(iii) of this section). See paragraph (a)(4), Example (4) of this section. * * * The referenced definition of consolidated adjusted net book income provides that the term means consolidated net book income after taking into account certain enumerated adjustments. Sec. 1.56-1(b)(3)(i), Income Tax Regs. Consolidated net book income, in turn, “is the income or loss of a consolidated group as reported on its applicable financial statement”. Sec. 1.56- 1(b)(3)(ii), Income Tax Regs. The applicable financial statement of a consolidated group “is the financial statement of the common parent” with the highest priority under ordering rules set forth in the regulatory section. Sec. 1.56-1(c)(5)(i), Income Tax Regs. Adjustments made to such financial statement include the addition of book income attributable to members of the consolidated group excluded from the applicable financial statement. Sec. 1.56-1(d)(6)(i), Income Tax Regs. Consolidated preadjustment AMTI is explained as “the taxable income of the consolidated group”, determined with the modifications prescribed in sections 56, 57, and 58 (except for the book income adjustment and the ATNOL). Sec. 1.56- 1(b)(3)(iii), Income Tax Regs. Example (4) of section 1.56-1(a)(4), Income Tax Regs. (hereinafter Example 4), illustrates the foregoing principles as follows:Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011