Intercorporate (or intra-entity) tax allocation (i.e., allocating income taxes to entities within a consolidated tax group) involves related parties and typically results from an expressed or implied agreement among the parties concerning the allocation of taxes currently payable. It is not uncommon for intercorporate tax-allocation agreements to be inconsistent with arrangements that might have been derived on an arm’s-length basis. ASC 850, Related Party Disclosures, recognizes that a subsidiary does not independently control its own actions and that most related-party transactions, including intercorporate tax allocations, might have been structured differently if the subsidiary had not been a controlled entity.
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