Part V—Members of a Controlled Group Treated as a Single Employer and FPMG Members…

If the corporation answers “Yes” to either Item A or Item B at the top of page 1, then the corporation must complete Part V. Enter the requested information for the entities included in the taxpayer’s applicable corporation determination.

Note: Incomplete or nonspecific responses, including phrases such as “available upon request” are not sufficient responses.

Column (a). Enter the name of the member of a controlled group and/or FPMG member included in the corporation’s applicable corporation determination.

Column (b). Enter the EIN of the member of a controlled group and/or FPMG member included in the corporation’s applicable corporation determination.

Column (c). Member of a controlled group. Check the box on the appropriate line if the entity is a member of a controlled group. See Proposed Regulations section 1.59-2(e)(1) for the definition of a controlled group.

Column (d). Check the box on the appropriate line if the entity is a member of an FPMG. See section 59(k)(2) and the AFSI Test section, earlier.

Column (e). Enter the EIN or foreign taxpayer identification number (FTIN) of the U.S. income tax return (if any) on which the majority of the member’s income is reported for the tax year. For this question only, majority means more than 50% of the member’s financial statement income.

Column (f). Enter each included member’s net income or loss reported on its AFS for the current tax year.