Form 851 

(Rev. October 2016) 

Department of the Treasury 

Internal Revenue Service 

Affiliations Schedule 

For tax year ending , 

▶ File with each consolidated income tax return. 

▶ Information about Form 851 and its instructions is at www.irs.gov/form851.

OMB No. 1545-0123 

Name of common parent corporation Employer identification number 

Number, street, and room or suite no. If a P.O. box, see instructions. 

City or town, state, and ZIP code 

Part I Overpayment Credits, Estimated Tax Payments, and Tax Deposits (see instructions) 

Corp. 

No. Name and address of corporation 

Employer 

 identification 

 number 

Portion of 

overpayment credits 

and estimated 

 tax payments 

Portion of tax 

deposited with 

Form 7004 

1 Common parent corporation 

2 

Subsidiary corporations: 

3 

4 

5 

6 

7 

8 

9 

10 

Totals (Must equal amounts shown on the consolidated tax return.) . . . . ▶

Part II Principal Business Activity, Voting Stock Information, Etc. (see instructions) 

Corp. 

No. Principal business activity (PBA) 

PBA 

Code 

No. 

Did the subsidiary 

make any nondividend 

distributions? 

Stock holdings at beginning of year 

Number 

of 

shares 

Percentage 

of voting 

power 

Percentage 

of value 

Owned by 

corporation 

 no. Yes No 

1 

Common parent corporation 

2 

Subsidiary corporations: 

% % 

3 % % 

4 % % 

5 % % 

6 % % 

7 % % 

8 % % 

9 % % 

10 % % 

For Paperwork Reduction Act Notice, see instructions. Cat. No. 16880G Form 851 (Rev. 10-2016) 
Form 851 (Rev. 10-2016) Page 2 

Part III Changes in Stock Holdings During the Tax Year 

Corp. 

No. Name of corporation 

Share- 

 holder of 

Corporation No. 

Date 

 of 

transaction 

(a) Changes 

(b) Shares held after 

changes described in 

column (a) 

 Number of 

shares 

acquired 

Number of 

shares 

disposed of 

Percentage of 

voting power 

Percentage of 

value 

% % 

% % 

% % 

% % 

% % 

% % 

% % 

% % 

(c) If any transaction listed above caused a transfer of a share of subsidiary stock (defined to include

dispositions and deconsolidations), did the share's basis exceed its value at the time of the transfer? See 

instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

(d) Did any share of subsidiary stock become worthless within the meaning of section 165 (taking into account 

the provisions of Regulations section 1.1502-80(c)) during the taxable year? See instructions . . . . Yes No

(e) If the equitable owners of any capital stock shown above were other than the holders of record, provide details of the changes. 

(f) If additional stock was issued, or if any stock was retired during the year, list the dates and amounts of these transactions. 

Form 851 (Rev. 10-2016) 
Form 851 (Rev. 10-2016) Page 3 

Part IV Additional Stock Information (see instructions) 

1 During the tax year, did the corporation have more than one class of stock outstanding? . . . . . . Yes No

If “Yes,” enter the name of the corporation and list and describe each class of stock. 

Corp. 

No. Name of corporation Class of stock 

2 During the tax year, was there any member of the consolidated group that reaffiliated within 60 months of

disaffiliation? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

If “Yes,” enter the name of the corporation(s) and explain the circumstances. 

Corp. 

No. Name of corporation Explanation 

3 During the tax year, was there any arrangement in existence by which one or more persons that were not 

members of the affiliated group could acquire any stock, or acquire any voting power without acquiring 

stock, in the corporation, other than a de minimis amount, from the corporation or another member of the 

affiliated group? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

If “Yes,” enter the name of the corporation and see the instructions for the percentages to enter in columns

(a), (b), and (c).

Corp. 

No. Name of corporation (a) 

Percentage of value

(b) 

Percentage of 

outstanding voting 

stock

(c) 

Percentage of 

voting power

% % % 

% % % 

% % % 

% % % 

Corp. 

No. (d) Provide a description of any arrangement. 

Form 851 (Rev. 10-2016) 
Form 851 (Rev. 10-2016) Page 4 

Instructions 

Section references are to the Internal Revenue 

Code unless otherwise noted. 

Future Developments

For the latest information about developments 

related to Form 851 and its instructions, such 

as legislation enacted after they were 

published, go to www.irs.gov/form851.

Purpose of Form 

Use Form 851 to: 

1. Identify the common parent corporation 

and each member of the affiliated group; 

2. Report the amount of overpayment 

credits, estimated tax payments, and tax 

deposits attributable to each corporation; and 

3. Determine that each subsidiary 

corporation qualifies as a member of the 

affiliated group. 

Who Must File 

The parent corporation must file Form 851 for 

itself and for corporations in the affiliated 

group. File Form 851 by attaching it to the 

consolidated tax return for the group. 

Affiliated Group 

An affiliated group is one or more chains of 

includible corporations connected through 

stock ownership with a common parent 

corporation. See sections 1504(a) and (b). The 

common parent must be an includible 

corporation and the following requirements 

must be met. 

1. The common parent must own directly 

stock that represents at least 80% of the total 

voting power and at least 80% of the total 

value of the stock of at least one of the other 

includible corporations. 

2. Stock that represents at least 80% of 

the total voting power, and at least 80% of 

the total value of the stock of each of the 

other corporations (except for the common 

parent) must be owned directly by one or 

more of the other includible corporations. 

For this purpose, the term “stock” generally 

doesn't include any stock that: 

1. Is nonvoting, 

2. Is nonconvertible, 

3. Is limited and preferred as to dividends 

and doesn't participate significantly in 

corporate growth, and 

4. Has redemption and liquidation rights 

that don't exceed the issue price of the stock 

(except for a reasonable redemption or 

liquidation premium). 

Address 

Include the suite, room, or other unit number 

after the street address. If the post office 

does not deliver mail to the street address 

and the corporation has a P.O. box, show the 

box number instead. 

Corporation Numbers 

When listing information in Parts II, III, and IV, 

use the same number for the common parent 

corporation and for each subsidiary 

corporation as the number listed in Part I. 

Part I 

Portion of overpayment credits and 

estimated tax payments. Enter for the 

common parent corporation and for each 

subsidiary corporation the amount of: 

• Overpayments of tax from the prior tax year 

that each corporation elected to credit to the 

current year's tax, and 

• Estimated tax payments made by each 

corporation. 

The total must be the same as the amounts 

entered on the lines for overpayments and 

estimated tax payments on the consolidated 

income tax return. 

Tax deposited with Form 7004. Enter for the 

common parent the tax deposited with Form 

7004, Application for Automatic Extension of 

Time To File Certain Business Income Tax, 

Information, and Other Returns, that is 

attributable to each corporation. The total 

must be the same as the amount entered on 

the “Tax deposited with Form 7004” line on 

the consolidated income tax return. 

Part II 

Principal business activity (PBA) and PBA 

Code No. Enter the PBA and the PBA code 

number for the common parent corporation 

and for each subsidiary corporation. Use the 

activity for the specific industry group from 

which the largest percentage of each 

corporation's total receipts is based. 

A list of the PBAs and code numbers is 

located in the Instructions for Form 1120.

Nondividend distributions. Nondividend 

distributions are any distributions (other than 

stock dividends and distributions in exchange 

for stock) made to shareholders during the 

tax year for which the consolidated tax return 

is filed that were in excess of the 

corporation's current and accumulated 

earnings and profits. See sections 301 and 

316 and Form 5452, Corporate Report of 

Nondividend Distributions. 

Part III 

Question (c). For this purpose, the term 

“transfer” includes transactions in which (1) a 

shareholder-member ceases to own a share 

of subsidiary stock in a transaction in which 

the shareholder-member recognizes income, 

gain, deduction, or loss on the stock; (2) a 

shareholder-member and the subsidiary 

cease to be members of the same 

consolidated group; and (3) a nonmember 

acquires the share from a member. If any type 

of transfer occurs and the share's basis would 

otherwise exceed its value at the time of the 

transfer, certain adjustments to members' 

bases in shares of the subsidiary's stock and 

to the subsidiary's attributes may be required. 

See Regulations section 1.1502-36.

Question (d). If a share of subsidiary stock 

becomes worthless within the meaning of 

section 165 (taking into account the 

provisions of Regulations section 

1.1502-80(c)) during the group's taxable year, 

certain adjustments to shareholder-members' 

bases in shares of the subsidiary's stock 

and/or to the subsidiary's attributes may be 

required. See Regulations sections 1.1502-19

(b)(1)(iv) (if the basis of the share is equal to or 

less than zero) and 1.1502-36 (if the basis of 

the share is greater than zero).

Item (e). The term “equitable owners” of 

stock means those that essentially have all 

the rights to enjoy the benefits of stock 

ownership without actually holding the stock, 

for example, beneficiaries of a trust. 

Part IV 

Question 1. For purposes of question 1 only, 

disregard certain preferred stock as described 

in section 1504(a)(4). 

Question 3. The term “arrangement” 

includes, but is not limited to, phantom stock, 

stock appreciation rights, an option, warrant, 

conversion feature, or similar arrangements. 

Item 3a. Show the percentage of the value of 

the outstanding stock that the person(s) could 

acquire. 

Item 3b. If the arrangement was associated 

with voting stock, show the percentage of 

outstanding voting stock that the person(s) 

could acquire. 

Item 3c. If the arrangement was associated 

with the acquisition of voting power without 

the acquisition of the related stock, show the 

percentage of voting power that the person(s) 

could acquire. 

Item 3d. Give a brief description of any 

arrangement (defined above) by which a 

person that is not a member of the affiliated 

group could acquire any stock, or acquire any 

voting power without acquiring stock, in the 

corporation. 

Paperwork Reduction Act Notice 

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carry out the Internal Revenue laws of the 

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are confidential, as required by section 6103. 

The time needed to complete and file this 

form will vary depending on individual 

circumstances. The estimated burden for 

business taxpayers filing this form is 

approved under OMB control number 

1545-0123 and is included in the estimates 

shown in the instructions for their business 

income tax return.

If you have comments concerning the 

accuracy of these time estimates or 

suggestions for making this form simpler, we 

would be happy to hear from you. See the 

instructions for the tax return with which this 

form is filed.