s. 179 and losses

[Corduroy Frog]

For purposes of discussion, please assume all companies are C Corps.

Alphabet, Inc. is a 100% owner of 4 subsidiaries,  W corp, X corp, Y corp, and Z corp.

W corp has a taxable loss, and reports s.179 depreciation.  X, Y, Z corp all operate profitably, to collectively exceed the loss reportable by W.

Question:  If Alphabet Inc. reports a consolidated return, does the s.179 survive as a current year deduction, or will the s.179 need to be carried forward until such time as W reports a taxable profit?

Offhand, I think on a consolidate return, the s.179 will be usable, but I thought it best to ask.

Thanks in advance --

[jklcpa]

see sec 179(b) on this page  and then more specifically further down same page at 179(b)(6)A) where it says :

Quote

(6)Dollar limitation of controlled groupFor purposes of subsection (b) of this section—

(A)

all component members of a controlled group shall be treated as one taxpayer, and

and then be sure to see this page for sec 1.179-2(b)(7) under the heading "Component members of a controlled group" about allocating among the members and the statement needed to be attached to the return

https://www.law.cornell.edu/cfr/text/26/1.179-2

[Corduroy Frog]

Good reading Judy.  Many aspects of s. 179 are discussed in detail.  In the simplest terms, the language "treated as one taxpayer" for a controlled group answers my question.

Thank you.