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The agreement calculates and allocates the tax consequences attributable to a specific member or group that are reported in a consolidated return. A TSA happens when two or more corporations are consolidated or combined into a single tax filing.
Broadly, tax sharing agreements: prevent joint and several liability arising by ?reasonably? allocating the group's income tax liability to group members.
Under the statute, a consolidated group can elect one of three main methods for allocating the group's tax liability for calculating the E&P of each member ? (1) based on the ratio of separate company taxable income to consolidated taxable income, (2) based on the percentage of total tax of the member versus all ...
Advantages of Filing a Consolidated Tax Return The deferment of taxable losses or taxable sales becomes realized with the ultimate sale to a third party. Capital losses and gains can also be spread out across affiliates. The income associated with one affiliated corporation can also be used to offset any losses.
Tax Sharing and Allocation Agreements are contracts that describe and coordinate the allocation of tax responsibility and benefits among the named parties for a particular transaction or for a specific taxable period. Depending on the context, they may be called different names.