- 13 - Corporations D and E are a consolidated group for tax purposes. D and E do not have a consolidated financial statement. On their separate financial statements D and E have adjusted net book income of $100 and $50 respectively, and preadjustment alternative minimum taxable income of $50 and $80 respectively. Assuming there are no intercompany transactions, DE’s consolidated adjusted net book income * * * is $150 and its consolidated pre-adjustment alternative minimum taxable income * * * is $130. DE must increase its consolidated pre-adjustment alternative minimum taxable income by $10 (($150 - $130) x .50). II. Overview and Positions of the Parties This controversy involves the intersection between the life- nonlife consolidated return rules and the AMT book income adjustment provisions. While each of the foregoing topics is the subject of a detailed and complex statutory and regulatory scheme, neither regime directly addresses how the two should be combined. By focusing on different aspects of the texts enacted or promulgated and their historical development, the parties here arrive at conflicting conclusions. To summarize the primary difference in their respective positions, petitioner maintains that the book income adjustment is to be computed on a “consolidated” basis, with a single adjustment for the entire group; respondent advocates a “subgroup” approach, with a separate book income adjustment for the life subgroup and for the nonlife subgroup. Petitioner approaches the problem at hand by focusing principally on the specific language of the statute and regulations addressing the book income adjustment. ThereinPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011