EXTENSION OF TIME FOR FILING FISCAL YEAR RETURNS OF PARTNERSHIPS AND PERSONAL SERVICE CORPORATIONS 1805. T. D. 2883. Extension of time for filing returns of partnerships and personal service corporations having a fiscal year ending prior to May 31, 1919.-An extension of time to August 15, 1919, for filing returns is hereby granted to partnerships and personal service corporations having a fiscal year ended January 31, February 28, March 31, or April 30, 1919. (T. D. 2883, approved July 9, 1919.) CAPITAL STOCK TAX CONSOLIDATED AND TENTATIVE RETURNS ¶ 1806. [See ¶ 1109] (9) Consolidated report for affiliated corporations.-Every corporation is required to file a return, but in many cases, as, for instance, in the case of selling agencies, separate corporations are formed in order to properly handle certain business under various State laws, and in reality are branches or departments of the parent corporations. The business is controlled by the parent corporation, and the result of operations is a matter of bookkeeping. The capital stock tax being imposed upon the fair value of the capital stock of corporations, it makes little difference by what method such fair value is determined, information under the three exhibits, or in a consolidated report, being furnished for the audit. Therefore, if affiliated corporations are best able to determine the fair value of the respective companies through a consolidated report, such privilege is permitted by the Department; but it seems preferable to leave this to the corporations interested, subject to approval by the Commissioner of Internal Revenue, rather than attempt to outline a specific method that would apply to all. It is not intended that T. D. 2493 shall again be used in this connection. Every corporation is taxable upon the fair value of its capital stock, independent of affiliated companies; but in some cases a combined statement is more effective in reflecting the fair value. (14) Tentative Returns.-Owing to numerous requests for rulings as to liability to capital stock tax and advice as to the proper procedure in completing forms, it is impossible to reply to all questions at a date which allows sufficient time for the taxpayer to complete and file return within the prescribed time. In order to avoid penalty for failure to file within the prescribed time, the first six lines of Form 707, or five lines of Form 708, may be completed, and together with a full and comprehensive statement of facts filed as a tentative return. This will apply particularly in the case of personal service corporations and where there is a question as to being engaged in business. Such cases may be referred later to this office for a ruling. [Paragraphs 9 and 14 of CST-Mim. 2150, dated June 11, 1919, and signed by Daniel C. Roper, Commissioner.] Regulations No. 57-Tax on Telegraph, Telephone, Radio and Cable Facilities.. 760 List of Forms Recently Released by the Treasury Department.. 775 Copyright, 1919. by Prentice-Hall, Inc., 757 1 66 ¶ 1807. Page 564. Certificate of residence-claim by aliens. "Reference is made to your letter, dated June 18, 1919, in regard to Article 315, Regulations 45, which is quoted here: "(b) The employer may also obtain evidence to overcome the prima facie presumption of the nonresidence by securing from the Alien Form 1078 (revised) or any equivalent certificate of the alien establishing residence. Having secured such evidence from the alien, the employer may rely thereon, unless the statement of the alien was false and the employer has reasonable cause to believe it false, and may continue to rely thereon until the alien ceases to be a resident under the provisions of Article 314.' "It is noted that you have been advised by the Collector of Internal Revenue at Baltimore that it will be necessary for the employer to obtain Form 1078 for each year that a nonresident alien was employed. "In reply you are advised that when Form 1078 is filed with the employer, the alien may be treated as a resident of the United States in so far as withholding of income tax at the source is concerned, and it is not necessary for the employer to secure from the alien employees new certificates, Form 1078, for each taxable year. The ruling contained in the article quoted herein will govern, namely, that when Form 1078 is filed, the employer may continue to rely thereon until the alien ceases to be a resident under the provisions of Article 314. "You are further advised that employers with whom Forms 1078 are filed should make a record of the certificates and forward them to the Commissioner of Internal Revenue, Sorting Division, Washington, D. C., not later than the twentieth day of the month succeeding that during which the certificates were received." [Letter to W. B. Reed, Accounting Secretary of the National Coal Association, signed by Commissioner Daniel C. Roper, and dated July 9, 1919.] ¶ 1808. Page 638. Invested capital for pre-war years.—“In response to your letter of June 5, 1919, inquiring whether a reduction in invested capital should be made in Schedule II of Form 1120 on account of the payment of excise taxes in prewar years, you are advised that the invested capital for any year during the pre-war period is determined in the same manner as for the taxable year. "The rule expressed in Article 845 of Regulations 45 that taxes are deemed to be paid out of earnings for the year for which levied, applies to any year of the pre-war period as well as to the taxable year. In such cases the amount or amounts |