South Carolina consolidated return allowed for members of different federal consolidated groups


A group of subsidiary corporations may file a South Carolina consolidated return even if they are included in separate federal consolidated groups or file separately for federal purposes when they are under the control of a common parent and have nexus with South Carolina. At least eighty percent of the total combined voting power of all classes of stock of all corporations that are a party to a consolidated return must be under the control of the same entity, but that control entity does not have to be part of the consolidated group [South Carolina Private Letter Ruling #12-4, 8/27/12].

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