The foreign subsidiaries of a U.S. corporation cannot be included in a U.S. consolidated tax return.

Name: The foreign subsidiaries of a U.S. corporation cannot be included in a U.S. consolidated tax return.
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Foreign subsidiaries are generally not eligible to be included in a U.S. consolidated tax return because the U.S. tax code allows only domestic corporations to be included in a consolidated tax return filing.

The Foreign Subsidiaries of a U