Foreign Entity Base Codes
A new series of apportionment bases (601- 665) is available in foreign entity binders. The 6xx bases are designed for use with nested divisional consolidations and provide a way to apportion an expense in a division binder using the results of its immediate divisional consolidation sub-group. For example:
- DivCon1 has members DivA, DivB and DivCon2
- DivCon2 has members DivC, DivD and DivCon3
- DivCon3 has members DivE and DivF
- 6xx in DivE will include the results of DivCon3 (DivE + DivF)
- 6xx in DivC will include the results of DivCon2 (DivC + DivD + DivCon3)
- 6xx in DivA will include the results of DivCon1 (DivA + DivB + DivCon2)
Similar to the 0xx bases, any amount apportioned on a 6xx base will be treated as if it were specifically sourced at the divisional consolidation level and will not be reapportioned during Look Through or Subpart F. As a result, different 6xx bases (or a combination of 6xx and 0xx bases) can be used for the same account in divisional consolidation members. However, when used in a legal entity, non-consolidated binder (such as a foreign parent or subsidiary), the 6xx bases produce the same result as the related 1xx and 0xx bases.
note
When you change a legal entity divisional consolidation to a hybrid division (International Entity Type of Division of Foreign Entity), you must change the 1xx base used in members of the hybrid divisional consolidation to a 6xx base to achieve the same apportionment. The 1xx base uses the consolidated financial amounts of the upper-tier legal entity divisional consolidation (rather than the lower-tier hybrid divisional consolidation) for apportionment.
