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of 8821/2848’s

Note:

Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States

Form 1120-F filer must provide a detailed explanation, including documentary evidence, as to why it believes it is entitled to certification.

If the application is for a corporate subsidiary, and the applicant failed to supply a copy of the consolidated return and/or the Schedule 851, research the corporate subsidiary's entity and tax module to verify that the applicant is recognized as a subsidiary by IRS.

Form 1120-14 filing requirement on the corporate subsidiary's entity indicates the entity is a subsidiary. The x-ref TIN must be that of the parent corporation.

A Transaction Code 590-14 in the subsidiary's tax module indicates that the subsidiary's 851 schedule was filed with the parent return, or that it has been verified as a subsidiary under the common parent corporation. The x-ref TIN must be that of the parent corporation.

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▸Contents — Internal Revenue Manual Part 21. Customer Account Services

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