When a group of corporations comes together to form an affiliated group for tax purposes, individual corporate members in the group may choose to file their own income tax return or file a group tax return; with an agreement of all the group members, they can elect to file a consolidated return. Imagine that a client is pursuing the acquisition of Corporation A that has a substantial net operating loss. Corporation B is a member of a controlled group and is currently included in a consolidated tax return that also has a net operating loss.

• Analyze the potential advantages and disadvantages of Corporation B’s acquisition of Corporation A and Corporation A’s subsequent inclusion in Corporation B’s consolidated tax return.
• Suggest the critical tax issues the client should consider in determining the deductibility of the net operating losses.
• Evaluate the impact of the Tax Cuts and Jobs Act (TCJA) on the net operating losses.