Addition of a Subsidiary to a Consolidated Group of Corporations

If the registrant is the parent corporation of a consolidated group, and it acquires a subsidiary that has a credit that will be monetized with an elective payment or transfer election on the registrant’s consolidated return, each facility/property owned by the subsidiary must be added to the parent corporation’s registration submission. Even if the subsidiary previously registered to monetize the credits (either on its own or as a subsidiary in another consolidated group), a change to the tax return on which the elective payment or transfer election will be made means that the registration must be associated with the annual tax return of the parent corporation.

Failure to add each facility/property owned by a subsidiary to the parent corporation’s registrations will cause any attempted elective payment or transfer election to become ineffective, even if that subsidiary’s facilities/ properties were previously registered. The registration numbers must be associated with the EIN of the return on which the election will be made.

Note: If the facility/property owned by the subsidiary already has a registration number, that information should be provided in the “Additional information” field of the registration submitted by the new parent corporation. So long as information about the facility/property is consistent with information provided in connection with the earlier registration, IRS review and reissuance of a registration number for that facility/ property may be streamlined.