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Some unfavorable tax results may occur from disaffiliation.
However, there clearly are some situations in which disaffiliation of a subsidiary can generate significant tax benefits.
Disaffiliation also can involve a profitable corporation becoming part of an affiliated group that has substantial loss carryforwards.
This lack of guidance has created uncertainty regarding whether disaffiliation has, in fact, taken place.
The second change to the consolidated return rules added by the DRA was a five-year waiting period between a corporation's disaffiliation and reconsolidation with the same affiliated group.
These rulings have permitted reconsolidation when the taxpayer established that the disaffiliation and reconsolidation did not secure for any of the affiliated groups or corporations involved the benefit of any deduction, credit or other allowance that would not otherwise have been available if disaffiliation and reconsolidation had not taken place.
The overriding factor cited in the letter rulings for securing a waiver is that the parent corporation must be able to represent that the disaffiliation and reconsolidation will not secure for any affiliated group, member of the affiliated group or person the benefit of any deduction, credit or other allowance that would not have been secured had disaffiliation and reconsolidation not occurred.
At CUNA, spokesperson Pat Keefe declined to reveal the number of CUNA members (NAFCU similarly declines to reveal its count), but Keefe did stress, disaffiliations aside, CUNA claims about 90% of credit unions as members.
The disaffiliations may serve as a wake-up call as more grumbling, about dues and measurable results, is heard from the credit unions that have to write the annual checks to maintain membership.
Jacobs said he had no knowledge of whether the disaffiliations of the two Albuquerque CUs were related to the departure in January of the $1.
The disaffiliation headache continued for CUNA this month with two large Albuquerque credit unions departing from the trade group and the Credit Union Association of New Mexico.
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