Minnesota Consolidation problem NOLs coming forward

Technical topics regarding tax preparation.
#1
jon  
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minnesota
Parent has a $200,000 NOL Carryforward and sub has a $2,000 NOL Carryforward to 2019.

2019 Parent sold stock and hat other investment income less salaries Parent has current Taxable Income $ 33,000 in 2019 Sub has a loss of $ (11,000) On the federal return the Consolidated income of $22,000 is wiped out by the consolidated NOLs (most before 2018). On the State return Ultra takes the federal NOL of $22,000 to Form M4T for both the Parent and the Sub, the line 2 is the apportionment %(sales) for each, and that is how the $22,000 is assigned to each!? So initially the program assigned all the taxable income to the SUB, subtracts the NOL of $2,000(80%of it) and they owe some State Income Taxes. I call and spend some time (a lot) saying this cannot be right. After 10 days they get back to me and they say the answer if just assign some sales to the apportionment (you can do that without causing any income tax change). So I do that but again that still prorates based on the totals, if I put a million in it would reduce to get most of income assigned to the Parent. Again on Minnesota all NOL carryforwards are subject to 80% of taxable income so some tax will result..

In the consolidated folder folder the Parent and Subs the M4Ts are perfect in their calculations of each. When it goes to the Consolidation it makes no sense. Ultra says put anything you want into in the Parent's sales for the apportionment schedule.

I think my choices are -(1)put a $1,000,0000 in the apportionment schedule (Probably would have to do less than the Million as it would cause an Apportionment Fee. (2) Override the apportionment %s on the M4T - would be 100% Parent and 0% for Sub? (3) Leave it as Ultra calculates ( I think they are saying it is wrong) or (4) what do you think.

There are no "surly" rules involved here the Parent formed the SUB in 2004 and there has been no changes in stock ownership.

Jon
 

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