Page:United States Statutes at Large Volume 78.djvu/95

 78 STAT. ]

PUBLIC LAW 88-272-FEB. 26, 1964

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"(2) ELECTION.—An election under this paragraph shall be made for an affiliated group by the common parent corporation, and shall be made for any taxable year of the common parent corl)oration at such time and in such manner as the Secretary or his delegate by regulations prescribes. Such election may not be made for an affiliated group for any taxable year of the common parent corporation for which an election under section 1562 is ^°®^' P- ^ineffective. Each corporation which is a member of such group at any time during its taxable year which includes the last day of such taxable year of the common parent corporation must consent to such election at such time and in such manner as the Secretary or his delegate by regulations prescribes. An election under this paragraph shall be effective— " (A) for the taxable year of each member of such affiliated group which includes the last day of the taxable year of the common parent corporation with respect to which the election is made (except that in the case of a taxable year of a member beginning in 1963 and ending in 1964, if the election is effective for the taxable year of the common parent corporation which includes the last day of such taxable year of such member, such election shall be effective for such taxable year of such member, if such member consents to such election with respect to such taxable year), and " (B) for the taxable year of each member of such affiliated group which ends after the last day of such taxable year of the common parent corporation but which does not include such date, unless the election is terminated under paragraph (4). " (3) EFFECT OF ELECTION.—If an election by an affiliated group is effective with respect to a taxable year of the common parent corporation, then under regulations prescribed by the Secretary or his delegate— " (A) no member of such affiliated group may consent to an election under section 1562 for such taxable year, " (B) the members of such affiliated group shall be treated as one taxpayer for purposes of making the elections under section 901(a) (relatuig to allowance of foreign tax credit) se^scT^go^i^^" and section 904(b)(1) (relating to election of overall limita- 74 Stat. 1010. tion),and 26 USC 904. " (C) the members of such affiliated group shall be limited to /-i / i \ / - .. ^ \

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and 809(d) (10),and _ " (v) $100,000 exemption for purposes of estimated tax filing requirements under section 6016 and the addition to tax under section 6655 for failure to pay estimated tax. "(4) TERMINATION.—An election by an affiliated group under paragraph (2) shall terminate with respect to the taxable year of the common parent corporation and with respect to the taxable years of the members of such affiliated group which Include the last day of such taxable year of the conmion parent corporation if—

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804.

26 USC 809. ^6 USC 6016. ^^ "^*-^ ^^^^•

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