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Official form guide
IRS Form 851 is the Affiliations Schedule used to report stock ownership and affiliated group information for consolidated return purposes. The form requires details on each member of an affiliated group, including stock ownership percentages and tax year-ends. No official source is available for this form.
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IRS Form 851 is the Affiliations Schedule used to report stock ownership and affiliated group information for consolidated return purposes. The form requires details on each member of an affiliated group, including stock ownership percentages and tax year-ends. No official source is available for this form.
Plain English
This form tells the IRS who owns which companies in a group of corporations that file taxes together. You list every company in the group and show how much stock each one holds in the others.
Submission Date
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Filer is a consolidated group with foreign subsidiaries
Required to compute foreign tax credits for consolidated groups
✓ Review current IRS instructions for Form 1118 and Revenue Procedure guidelines
Filer needs to elect or terminate consolidated return status
The affiliations schedule is part of the consolidated return package; separate forms trigger elections
✓ Verify that the election or termination is properly documented according to Treasury Regulation §1.1502
Filer is an affiliated group but not filing a consolidated return
Members must file individually when no consolidated return is elected
✓ Check that each member meets the definition of an affiliated group under IRC §1504
Separate Forms 1120 for each member
Filer needs to reflect a change in affiliated group composition during the year
Schedule O reports changes in stock ownership that affect group membership
✓ Confirm that all changes are reported for the correct period and that no duplicate entries exist
Filer is insolvent or in bankruptcy
Filing requirements differ for insolvent members; special rules apply to deductions and credits
✓ Consult IRS guidance for bankruptcy filings and ensure proper treatment of NOLs and credits
Form 1120, Form 851, and Bankruptcy schedule
Not stated in the official source.
Checklist
Header (name, EIN, tax year)
Legal business name and current EIN · IRS records or prior year return
List of members
Stock ownership percentages for each member · Stock certificates, corporate records, shareholder agreements
Schedule O (stock ownership changes)
Dates and details of stock purchases or sales · Board minutes, closing documents, stock transfer ledger
Schedule P (life insurance member)
Life insurance company status and tax reporting · NAIC annual statement, state insurance filings
Schedule Q (consolidated return election)
Consent of each member to join consolidated return · Resolutions, letters from members
Schedule R (affiliated group changes)
Effective dates of acquisition or deconsolidation · Purchase agreements, notices from IRS
Signature block
Date and signature of authorized officer · Corporate by-laws, authorization records
Field map
General Info
2 items
Full legal name and taxpayer identification number (SSN or EIN).
Current mailing address.
Details
2 items
Complete all applicable sections of this form according to the official IRS instructions.
Enter the relevant dollar amount if this form involves tax calculation.
Certification
1 items
Read and acknowledge any certifications required by this form.
Signatures
1 items
Sign and date. Unsigned forms cannot be processed.
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Fillable formOpen in Editor->No official source is available for IRS Form 851. The current edition revision date is not stated in the official source — verify on the IRS website.
Quick Facts
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Do I list every subsidiary even if it's dormant?
The form requires all members of the affiliated group regardless of activity, but dormant companies may be omitted if they meet certain exceptions under Reg. §1.1502-76
→ Confirm that the subsidiary is indeed a member as defined in IRC §1504(a) and review Reg. §1.1502-76(b) for exceptions
What stock ownership percentage do I report for foreign subsidiaries?
Foreign subsidiaries are generally not members for domestic consolidated return purposes but may still need to be listed for information purposes
→ Verify that you are reporting only domestic members for the consolidated return and that foreign subsidiaries are disclosed only if required by the instructions
How do I handle a subsidiary that was sold during the year?
The form requires reporting of the subsidiary for the portion of the year it was a member, and Schedule O or Schedule R should reflect the disposition
→ Report the ownership % for the months owned and attach a statement explaining the sale date and gain/loss
Do I need to file Form 851 for every amendment to a consolidated return?
Form 851 is part of the original return; amendments may require a corrected Form 851 only if affiliation changed
→ Check the IRS guidance for amended returns; if no change in membership, attach a statement referencing the original Form 851
What if my group has 200 members?
The form has a limited number of lines; attach additional schedules as needed
→ Use the prescribed format from the instructions for continuation sheets and ensure the total stock ownership adds to 100% for each tier
Can I use last year's Form 851 for this year?
No, the form must reflect the current tax year's affiliation and ownership
→ Compare the old form to current records and update all members, ownership percentages, and tax year-ends
Is the form required if I am not filing a consolidated return?
The form is specifically for consolidated returns; if not filing consolidated, no Form 851 is needed
→ Confirm that your group qualifies for consolidated treatment and that you intend to file Form 1120 consolidated
What does 'affiliated group' mean in this context?
It means a chain of includible corporations meeting the 80% voting and value test under IRC §1504
→ Review IRC §1504(a) and ensure each member is a domestic corporation not excluded by §1504(b)
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⚠ If something goes wrong
This form tells the IRS who owns which companies in a group of corporations that file taxes together. You list every company in the group and show how much stock each one holds in the others.
The form requires all members of the affiliated group regardless of activity, but dormant companies may be omitted if they meet certain exceptions under Reg. §1.1502-76 Confirm that the subsidiary is indeed a member as defined in IRC §1504(a) and review Reg. §1.1502-76(b) for exceptions
Foreign subsidiaries are generally not members for domestic consolidated return purposes but may still need to be listed for information purposes Verify that you are reporting only domestic members for the consolidated return and that foreign subsidiaries are disclosed only if required by the instructions
The form requires reporting of the subsidiary for the portion of the year it was a member, and Schedule O or Schedule R should reflect the disposition Report the ownership % for the months owned and attach a statement explaining the sale date and gain/loss
Form 851 is part of the original return; amendments may require a corrected Form 851 only if affiliation changed Check the IRS guidance for amended returns; if no change in membership, attach a statement referencing the original Form 851
The form has a limited number of lines; attach additional schedules as needed Use the prescribed format from the instructions for continuation sheets and ensure the total stock ownership adds to 100% for each tier
No, the form must reflect the current tax year's affiliation and ownership Compare the old form to current records and update all members, ownership percentages, and tax year-ends
The form is specifically for consolidated returns; if not filing consolidated, no Form 851 is needed Confirm that your group qualifies for consolidated treatment and that you intend to file Form 1120 consolidated
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