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Foreign Divisional Consolidations
The system gives you the ability to treat foreign subsidiaries, parents, and divisional consolidations as foreign disregarded entities (FDEs) without creating new entities and binders.
You can:
- Expand the entities available as members of a foreign divisional consolidation.
- Automate the preparation of Form 8858 in foreign subsidiaries, parents, and divisional consolidations.
- Process nested or tiered divisional consolidation structures during Tax Accounting System (TAS) consolidation and E&P computes.
note
The membership of domestic divisional consolidations (international filing type none or foreign tax credit) is limited to divisions.
Members available to select
A foreign divisional consolidation can be a foreign partnership, controlled foreign corporation, or 10/50 company.
Entities you can select and include as a member of a foreign divisional consolidation:
- an entity type of Divisional Consolidation
- an international filing type of foreign entity
- an entity type of division, divisional consolidation, parent, or subsidiary
- an international entity type of division of foreign entity
How TAS facilitates the process
In a foreign divisional consolidation binder, the
TAS Consolidation
screen looks through any divisional consolidations on the members list and presents the lower-tier (nested) consolidations and their members in the compute grid. This drill-down process continues until all consolidations are displayed. When you compute/consolidate foreign entities in a Top Consolidation binder, the TAS embedded consolidation similarly processes nested divisional consolidations.In addition to the Form 8858 created in foreign and foreign tax credit (domestic) divisions, TAS automatically generates a single-instance of the Form 8858 in the Organizer for income tax binders with:
- an international filing type of foreign entity
- a return type of 1120 US Corporation
- an entity type of Divisional Consolidation, parent, or subsidiary
When a foreign divisional consolidation gets treated as a member (division) of another divisional consolidation, the system produces a consolidated Form 8858 which can be filed for the nested entity. TAS transfers consolidated amounts to the Form 8858; the Organizer in the foreign divisional consolidation doesn't consolidate the Form 8858s in the member binders.
TAS foreign entity sourcing, country coding (if a foreign partnership), current year tax payments and interest apportionment information entered in the members of a foreign divisional consolidation are aggregated during TAS consolidation/compute if sourcing gets completed at the division level. If a nested divisional consolidation structure gets used, the system consolidates this information in both the upper-tier and the lower-tier(s) binders.
The system gives you the ability to record and process a foreign divisional consolidation's intercompany payments and receipts at either the foreign divisional consolidation or member (division) level.
When a foreign divisional consolidation sources at the division level, the system allows you to:
- Record intercompany rent, royalty or interest payments/receipts between the foreign divisional consolidation's member (division) binders and a domestic/foreign legal entity or foreign division that is a member of another divisional consolidation with options set to enter intercompany transactions at the division level.
- Enter an intercompany dividend payment from a foreign legal entity (parent, subsidiary or divisional consolidation) to a domestic/foreign legal entity or a foreign division that's a member of a foreign divisional consolidation with options set to enter intercompany transactions at the division level. A foreign division cannot be a dividend payor.
- Manual adjustments must be made to remove (reclass) any amounts that represent intracompany transactions between divisions (or divisional consolidation) that are members of the same divisional consolidation. During Look Through calculations, comprehensive edit errors will occur if any intracompany transactions are present.
This article applies to:
- PRODUCT: ONESOURCE Income Tax
- Return type: 1120 Corporation
- Subject: Consolidations