Suggestions I can offer Sandra and John about the short-term possibility of using Alpha’s and Beta’s NOLs against the profits that Alpha expects to earn and about minimizing their overall tax liabilities if both businesses become profitable. Suggestion one will be that they can control their shares of the corporation together for five years without being able to file a consolidated tax return. Suggestion two If Sandra and John want to be able to file a consolidated tax return on their shares they can convert their corporations into a parent – subsidiary corporate structure from a brother – sister corporation structure. Sandra and John can also choice to do a nontaxable merger of one corporation into the other. If Sandra and John agree to
