SECTION 5. STATEMENT OF

ELECTION

A consolidated group makes the retroactive single-entity election by filing a separate statement by the time, and in the manner, prescribed in Section 6 or 7, as applicable. The statement must be signed by the common parent and must say, ‘‘[INSERT NAME AND EMPLOYER IDENTIFICATION NUMBER OF COMMON PARENT] hereby elects the retroactive application of section 1.1221–2(d)(1) (the single-entity approach) beginning with [IDENTIFY THE ELECTION YEAR].’’ The statement of election must also contain a list of the affected years for which the federal income tax returns are inconsistent with the single-entity election or must state that the federal income tax returns for all affected years are consistent with the single-entity election.