Memorandum TSB-M-08(2)(C) replaces TSB-M-07(6)(C) for "Combined Reporting for General Business Corporations (including REITs, RICs, & Insurance Corporations" and is effective for tax years beginning after January 1, 2007.
The new memorandum provides that a corporation must file a combined report with other related corporations where there are substantial intercorporate transactions among related corporations.
Pease see the new memorandum for definition of key terms including, related corporation, substantial intercorporate transactions, substantial intercorporate receipts & expenditures, et al.
I am unaware what is meant by "retroactively for 2009" as there does not appear to be any other combined return guidance other than this memorandum.
answered 26 Nov '09, 00:36