Corporate Subsidiary Applicants
Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States
A U.S. corporation that is a subsidiary of another corporation may be a member of a consolidated group. A corporation that is a subsidiary of another corporation is included in that corporation's consolidated return.
The subsidiary is an affiliate defined in IRC 1504 (i.e., child) of the corporation.
The corporation that is liable for filing the corporate tax return is the common parent corporation.
The consolidated return, Form 1120, must be filed by the common parent corporation.
The consolidated return is the tax return which includes the information pertaining to the parent and all its affiliates' (subsidiaries’) information.
A corporate subsidiary applicant that filed a Form 1120-F, generally is not entitled to U.S. Residency Certification. If the subsidiary filed Form 1120-F, and believes it is entitled to U.S. Residency Certification under a specific treaty article, refer the applicant to Rev. Proc. 2015-40.
A corporate subsidiary applicant that has a filing requirement of Form 1120-F, is not entitled to U.S. Residency Certification. Issue Letter 4057.
If the applicant claims during a telephone conversation the filing requirement is incorrect, refer to Customer Service at 800-829-4933.
If the applicant submits correspondence stating the filing requirement is incorrect, forward to Entity to request a Filing requirement determination using Form 4442.
If filing requirement is corrected, issue certification.
A corporate subsidiary applicant's Form 8802 must include:
Application Information (Name of applicant for which certification is being requested)
Applicant's TIN, EIN (the subsidiary)
Mailing Address (if other than applicant's address)
Permanent Residence Address (when applicable)
Parent Corporation, Entity information
Parent Corporation's EIN
Entity Type must be corporate
Tax Form Filed
Requested certification year (the year the applicant wants printed on the Form 6166)
Tax period
Certification Type
Country and number of certifications requested
TIA (when applicable)
Penalties of Perjury statements (when applicable)
A signature and date
A signed copy of page one of the consolidated return filed
A copy of Schedule 851, Affiliation Schedule
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