Intragroup Wars: Abusive Parents, Rebellious Subsidiaries
In good times, tax sharing agreements (TSAs) and intercompany tax payments between members of a consolidated group are boring topics. They may affect the accounting treatment of deferred tax assets or calculations of stock basis, earnings and profits, and other tax attributes of various members of the group, and they may periodically raise questions of interpretation. But these issues usually do not require the services of a litigator. As long as the group remains one happy family, it is hard to imagine members of the group suing each other over a tax refund.