Ruling 89-46
Corporation Business Tax
You have inquired as to whether a corporation that makes a I.R.C. § 338(h)(10) election will be allowed that treatment for the purposes of the Connecticut Corporation Business Tax.
It is our conclusion that, for the purposes of the Connecticut Corporation Business Tax, this Department will follow federal law incorporating the effects of an I.R.C. § 338(h)(10) election in computing tax liability.
LEGAL DIVISION
August 15, 1989