I'm writing a comparative paper on US and swedish tax regulations for results equalisation within a company group, i.e. lowering taxation.

In Sweden a "koncernbidrag" is used for this. The way it works in its most simple form is this:

Company A owns company B (90% of the shares or more required). Before taxation company B is showing a loss and company A is showing a profit. Company A can then transfer resources (with tax-reducing effect) to company B thus lowering the taxation on the company group.

The idea behind this is that it shouldn't make a difference taxwise in how you organise your operations. Had all activities in the above example happened within a single company all incomes and costs would have been set-off against each other which is roughly what happens after using the "koncernbidrag"

I hope the above makes sense, if not please ask me to clarify.

I would like to know in what sense the US has corresponding regulations to this and where I can find them. I also would like to know if there are comments (articles etc) to the us regulations since everything may not be completely understandable for a foreigner at first glance.

Hope someone has the time to help me.

Thank you.