Treasury Regulations · 26 CFR
§ 1.1502-1. Definitions.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 1502
Cite as 26 CFR § 1.1502-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- September 8, 1966 by T.D. 6894
- Last amended
- December 30, 2024 by T.D. 10018
- Issued under
- 26 U.S.C. § 1502
- Length
- 877 words · about 4 min to read
- Defines
- 11 terms
- Cross-references
- cites 2 Code sections and 1 regulation; cited by 72
For purposes of the consolidated return regulations (and any provision of this chapter that refers to the consolidated return regulations):
¶(a) Group. The term group means an affiliated group of corporations as defined in section 1504. See § 1.1502-75(d) as to when a group remains in existence. Except as the context otherwise requires, references to a group are references to a consolidated group (as defined in paragraph (h) of this section).
¶(b) Member. The term member means a corporation (including the common parent) that is included in the group, or as the context may require, a corporation that is included in a subgroup.
¶(c) Subsidiary. The term subsidiary means a corporation other than the common parent which is a member of such group.
¶(d) Consolidated return year. The term consolidated return year means a taxable year for which a consolidated return is filed or required to be filed by such group.
¶(e) Separate return year. The term separate return year means a taxable year of a corporation for which it files a separate return or for which it joins in the filing of a consolidated return by another group.
¶(f) Separate return limitation year—
¶(1) In general. Except as provided in paragraphs (f)(2) and (3) of this section, the term separate return limitation year (or SRLY) means any separate return year of a member or of a predecessor of a member.
¶(2) Exceptions. The term separate return limitation year (or SRLY) does not include:
¶(i) A separate return year of the corporation which is the common parent for the consolidated return year to which the tax attribute is to be carried (except as provided in § 1.1502-75(d)(2)(ii) and paragraph (f)(3) of this section);
¶(ii) A separate return year of any corporation which was a member of the group for each day of such year; or
¶(iii) A separate return year of a predecessor of any member if such predecessor was a member of the group for each day of such year.
¶(3) Reverse acquisitions. In the event of an acquisition to which § 1.1502-75(d)(3) applies, all taxable years of the first corporation and of each of its subsidiaries ending on or before the date of the acquisition are treated as separate return limitation years, and the separate return years (if any) of the second corporation and each of its subsidiaries are not treated as separate return limitation years (unless they were so treated immediately before the acquisition). For example, if corporation P merges into corporation T, and the persons who were stockholders of P immediately before the merger, as a result of owning the stock of P, own more than 50 percent of the fair market value of the outstanding stock of T, then a loss incurred before the merger by T (even though it is the common parent), or by a subsidiary of T, is treated as having been incurred in a separate return limitation year. Conversely, a loss incurred before the merger by P, or by a subsidiary of P in a separate return year during all of which such subsidiary was a member of the group of which P was the common parent, is treated as having been incurred in a year which is not a separate return limitation year.
¶(4) Predecessor and successors. The term predecessor means a transferor or distributor of assets to a member (the successor) in a transaction—
¶(ii) That occurs on or after January 1, 1997, in which the successor's basis for the assets is determined, directly or indirectly, in whole or in part, by reference to the basis of the assets of the transferor or distributor, but in the case of a transaction that occurs before June 25, 1999, only if the amount by which basis differs from value, in the aggregate, is material. For a transaction that occurs before June 25, 1999, only one member may be considered a predecessor to or a successor of one other member.
¶(g) Consolidated return regulations. The term consolidated return regulations means the regulations issued under the authority of section 1502.
¶(h) Consolidated group. The term “consolidated group” means a group filing (or required to file) consolidated returns for the tax year.
¶(i) [Reserved]
¶(j) Affiliated. Corporations are affiliated if they are members of a group with each other.
¶(l) U.S. territory. The term U.S. territory means—
¶(1) American Samoa;
¶(2) The Commonwealth of the Northern Mariana Islands;
¶(3) The Commonwealth of Puerto Rico;
¶(4) Guam; and
¶(5) The U.S. Virgin Islands.
¶(m) Applicability date. Paragraph (k) of this section applies to taxable years beginning after December 31, 2020. However, a taxpayer may choose to apply paragraph (k) of this section to taxable years beginning on or before December 31, 2020.
[T.D. 6894, 31 FR 11794, Sept. 8, 1966, as amended by T.D. 7246, 38 FR 758, Jan. 4, 1973; T.D. 8294, 55 FR 9434, Mar. 14, 1990; T.D. 8319, 55 FR 49038, Nov. 26, 1990; T.D. 8560, 59 FR 41675, Aug. 15, 1994; T.D. 8677, 61 FR 33325, June 27, 1996; T.D. 8823, 64 FR 36101, July 2, 1999; T.D. 9927, 85 FR 67974, Oct. 27, 2020; T.D. 10018, 89 FR 106852, Dec. 30, 2024]
Terms defined here
Where the text says “the term … means”. Select a term to jump to its definition.
- consolidated group § 1.1502-1(h)
- consolidated return regulations § 1.1502-1(g)
- consolidated return year § 1.1502-1(d)
- group § 1.1502-1(a)
- member § 1.1502-1(b)
- nonlife insurance company § 1.1502-1(k)
- predecessor § 1.1502-1(f)(4)
- separate return limitation year § 1.1502-1(f)(1)
- separate return limitation year § 1.1502-1(f)(2)
- separate return year § 1.1502-1(e)
- subsidiary § 1.1502-1(c)
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
Cited by 72 other regulations
- § 1.41-6 Aggregation of expenditures.
- § 1.45G-1 Railroad track maintenance credit.
- § 1.45X-2 Sale to unrelated person.
- § 1.45Y-1 Clean electricity production credit.
- § 1.162-31 The $500,000 deduction limitation for remuneration provided by certain health insurance providers.
- § 1.163(j)-1 Definitions.
- § 1.163(j)-5 General rules governing disallowed business interest expense carryforwards for C corporations.
- § 1.163(j)-9 Elections for excepted trades or businesses; safe harbor for certain REITs.
- § 1.168(d)-1 Applicable conventions—half-year and mid-quarter conventions.
- § 1.168(k)-2 Additional first year depreciation deduction for property acquired and placed in service after September 27, 2017.
- § 1.179B-1T Deduction for capital costs incurred in complying with Environmental Protection Agency sulfur regulations (temporary).
- § 1.245A-5 Limitation of section 245A deduction and section 954(c)(6) exception.
- § 1.250(a)-1 Deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).
- § 1.250(b)-1 Computation of foreign-derived intangible income (FDII).
- § 1.263A-9 The avoided cost method.
- § 1.337(d)-1 Transitional loss limitation rule.
- § 1.337(d)-2 Loss limitation rules.
- § 1.338(h)(10)-1 Deemed asset sale and liquidation.
- § 1.367(a)-3 Treatment of transfers of stock or securities to foreign corporations.
- § 1.367(a)-8 Gain recognition agreement requirements.
- § 1.382-8 Controlled groups.
- § 1.385-3 Certain distributions of debt instruments and similar transactions.
- § 1.385-4 Treatment of consolidated groups.
- § 1.446-3 Notional principal contracts.
Show 48 more
- § 1.451-3 Timing of income inclusion for taxpayers with an applicable financial statement using an accrual method of accounting.
- § 1.451-8 Advance payments for goods, services, and certain other items.
- § 1.460-6 Look-back method.
- § 1.469-1 General rules.
- § 1.475(c)-1 Definitions—dealer in securities.
- § 1.597-1 Definitions.
- § 1.636-4 Effective dates of section 636.
- § 1.704-1 Partner's distributive share.
- § 1.704-3 Contributed property.
- § 1.706-1 Taxable years of partner and partnership.
- § 1.721(c)-3 Gain deferral method.
- § 1.721(c)-5 Acceleration event exceptions.
- § 1.732-3 Corresponding adjustment to basis of assets of a distributed corporation controlled by a corporate partner.
- § 1.761-3 Certain option holders treated as partners.
- § 1.901(m)-1 Definitions.
- § 1.907(c)-2 Section 907(c)(3) items (for taxable years beginning after December 31, 1982).
- § 1.951A-1 General provisions.
- § 1.965-8 Affiliated groups (including consolidated groups).
- § 1.987-1 Scope, definitions, and special rules.
- § 1.987-11 Suspended section 987 loss relating to certain elections; loss-to-the-extent-of-gain rule.
- § 1.1362-3 Treatment of S termination year.
- § 1.1362-8 Dividends received from affiliated subsidiaries.
- § 1.1400Z2(a)-1 Deferring tax on capital gains by investing in opportunity zones.
- § 1.1502-0 Effective/applicability dates.
- § 1.1502-3 Consolidated tax credits.
- § 1.1502-4 Consolidated foreign tax credit.
- § 1.1502-9 Consolidated overall foreign losses, separate limitation losses, and overall domestic losses.
- § 1.1502-14Z Application of opportunity zone rules to members of a consolidated group.
- § 1.1502-15 SRLY limitation on built-in losses.
- § 1.1502-21 Net operating losses.
- § 1.1502-47 Consolidated returns by life-nonlife groups.
- § 1.1502-59A Application of section 59A to consolidated groups.
- § 1.1502-75 Filing of consolidated returns.
- § 1.1502-77 Agent for the group.
- § 1.1502-78 Tentative carryback adjustments.
- § 1.1502-91 Application of section 382 with respect to a consolidated group.
- § 1.1502-92 Ownership change of a loss group or a loss subgroup.
- § 1.1502-95 Rules on ceasing to be a member of a consolidated group (or loss subgroup).
- § 1.1502-96 Miscellaneous rules.
- § 1.1503(d)-1 Definitions, special rules, and filings.
- § 1.1503(d)-4 Domestic use limitation and related operating rules.
- § 1.1503(d)-6 Exceptions to the domestic use limitation rule.
- § 1.1502-77B Agent for the group applicable for consolidated return years beginning on or after June 28, 2002, and before April 1, 2015.
- § 1.6417-2 Rules for making elective payment elections.
- § 1.6418-2 Rules for making transfer elections.
- § 1.6418-4 Additional information and registration.
- § 1.6655-5 Short taxable year.
- § 301.6402-7 Claims for refund and applications for tentative carryback adjustments involving consolidated groups that include insolvent financial institutions.
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Amended by T.D. 10018 (89 FR 106852)
- Amended by T.D. 9927 (85 FR 67974)
- Amended by T.D. 8823 (64 FR 36101)
- Amended by T.D. 8677 (61 FR 33325)
- Amended by T.D. 8560 (59 FR 41675)
- Amended by T.D. 8319 (55 FR 49038)
- Amended by T.D. 8294 (55 FR 9434)
- Amended by T.D. 7246 (38 FR 758)
- Issued by T.D. 6894 (31 FR 11794)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Consolidated Return Regulations
Nearby sections
- § 1.1502-0 Effective/applicability dates.
- § 1.1502-1 Definitions.