Can the credit be assigned to a division?
No. The credit cannot be assigned to a division if “division” is defined as a group of corporations in the same line of business within the entire combined reporting group. The assignor taxpayer can only assign to a specific corporation, not a group of corporations. A single owner eligible business entity (including a single member LLC) that is disregarded as an entity separate from its owner is treated as a division of the parent company of the disregarded entity. All of the expenses, receipts, property, etc., of the disregarded entity would then be treated as if they were the expenses, receipts, property, etc., of the owner. Special rules limit the amount of credit that can be used to offset tax to only the amount of tax attributable to the income of the otherwise disregarded entity. This limitation would apply to assigned credits as well. Special rules limit the amount of credit that can be used to offset tax to only the amount of tax attributable to the income of the otherwise disr
