A corporation organized in Germany and wholly owned by the U.S. parent can be included in a Federal consolidated return.

Name: A corporation organized in Germany and wholly owned by the U.S. parent can be included in a Federal consolidated return.
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A corporation must be incorporated in the United States to be included in a Federal consolidated tax return; foreign corporations, even if wholly owned by a U.S. parent, are not eligible.

A Corporation Organized in Germany and Wholly Owned by the U.S