Treasury Regulations (26 C.F.R.)
26 CFR § 1.1502-6
Liability for tax.
# (a) Several liability of members of group.
Except as provided in paragraph (b) of this section, the common parent corporation and each subsidiary which was a member of the group during any part of the consolidated return year shall be severally liable for the tax for such year computed in accordance with the regulations under section 1502 prescribed on or before the due date (not including extensions of time) for the filing of the consolidated return for such year.
# (b) Liability of subsidiary after withdrawal.
If a subsidiary has ceased to be a member of the group and in such cessation resulted from a bona fide sale or exchange of its stock for fair value and occurred prior to the date upon which any deficiency is assessed, the Commissioner may, if the Commissioner believes that the assessment or collection of the balance of the deficiency will not be jeopardized, make assessment and collection of such deficiency from such former subsidiary in an amount not exceeding the portion of such deficiency which the Commissioner may determine to be allocable to it. If the Commissioner makes assessment and collection of any part of a deficiency from such former subsidiary, then for purposes of any credit or refund of the amount collected from such former subsidiary the agency of the common parent under the provisions of § 1.1502-77 does not apply.
# (c) Effect of intercompany agreements.
No agreement entered into by one or more members of the group with any other member of such group or with any other person shall in any case have the effect of reducing the liability prescribed under this section.
[T.D. 6894, 31 FR 11794, Sept. 8, 1966, as amended by T.D. 9002, 67 FR 43540, June 28, 2002; T.D. 10018, 89 FR 106853, Dec. 30, 2024]
Source: view the official text
In this part (40 sections)
- 1.1471-3 · Identification of payee.
- 1.1471-4 · FFI agreement.
- 1.1471-5 · Definitions applicable to section 1471.
- 1.1471-6 · Payments beneficially owned by exempt beneficial owners.
- 1.1472-1 · Withholding on NFFEs.
- 1.1473-1 · Section 1473 definitions.
- 1.1474-1 · Liability for withheld tax and withholding agent reporting.
- 1.1474-2 · Adjustments for overwithholding or underwithholding of tax.
- 1.1474-3 · Withheld tax as credit to beneficial owner of income.
- 1.1474-4 · Tax paid only once.
- 1.1474-5 · Refunds or credits.
- 1.1474-6 · Coordination of chapter 4 with other withholding provisions.
- 1.1474-7 · Confidentiality of information.
- 1.1481-1 · [Reserved]
- 1.1502-0 · Effective/applicability dates.
- 1.1502-1 · Definitions.
- 1.1502-2 · Computation of tax liability.
- 1.1502-3 · Consolidated tax credits.
- 1.1502-4 · Consolidated foreign tax credit.
- 1.1502-5 · Estimated tax.
- 1.1502-6 · Liability for tax.
- 1.1502-9 · Consolidated overall foreign losses, separate limitation…
- 1.1502-11 · Consolidated taxable income.
- 1.1502-12 · Separate taxable income.
- 1.1502-13 · Intercompany transactions.
- 1.1502-14Z · Application of opportunity zone rules to members of a…
- 1.1502-15 · SRLY limitation on built-in losses.
- 1.1502-16 · Mine exploration expenditures.
- 1.1502-17 · Methods of accounting.
- 1.1502-19 · Excess loss accounts.
- 1.1502-21 · Net operating losses.
- 1.1502-22 · Consolidated capital gain and loss.
- 1.1502-23 · Consolidated net section 1231 gain or loss.
- 1.1502-24 · Consolidated charitable contributions deduction.
- 1.1502-26 · Consolidated dividends received deduction.
- 1.1502-28 · Consolidated section 108.
- 1.1502-30 · Stock basis after certain triangular reorganizations.
- 1.1502-31 · Stock basis after a group structure change.
- 1.1502-32 · Investment adjustments.
- 1.1502-33 · Earnings and profits.