If a unitary group files a single group return using the combined reporting method, how do the unitary members compute the $1 million understatement of tax threshold?
If two or more corporations are required to be included in a combined report under R&TC Section 25101, or are authorized to be included in a combined report under R&TC Section 25101.15, the $1 million threshold amount applies to the aggregate amount of the tax liability of all taxpayers that are required or authorized to be included in the combined report. (R&TC Section 19138(a)(2).
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