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While ASC 740 does not explicitly state the level of application of the intraperiod allocation rules, implicitly the intraperiod allocation rules should be applied at the jurisdictional level when only one return is filed within a jurisdiction and at the tax-return level when more than one tax return is filed within a jurisdiction (e.g., where a consolidated tax return is not filed). See ASC 740-10-30-5. Applying the intraperiod allocation rules at the proper level can require a significant amount of attention for multi-jurisdictional entities, especially when a valuation allowance is increased or decreased during the year within a jurisdiction.
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