How may a corporation share refundable and nonrefundable tax credits and nonrefundable tax credit carryforwards under combined reporting?
In general, refundable and nonrefundable tax credits and nonrefundable tax credit carryforwards are available only to the separate corporation that generated them.
An exception applies for the nonrefundable portion of the research expense credit and the research facilities credit under sec. 71.28(4) and (5) or 71.47(4) and (5), Wis. Stats., and the carryforward of these credits. A corporation may share all or a portion of the unused credit with the other members of the combined group in the manner provided under sec. 71.255(6)(c), Wis. Stats., and sec. Tax 2.61(10), Wisconsin Administrative Code.
This sharing applies only to the two aforementioned credits; the super research and development credit, which became effective for taxable years beginning on or after January 1, 2011, and before January 1, 2014, under sec. 71.28(4m) or 71.47(4m), Wis. Stats., may not be shared.
Each member of a combined group reports its refundable tax credits on Form 6, Part III, line 13. Each member will report its nonrefundable tax credits on Form 6, Part V. Combined groups that share its members' nonrefundable research expense and research facilities credits should prepare
Wisconsin Sharing of Research Credits, and show the amount allocated to each member on the Form 6, Part V.