Article 51 - Additional Tax for Permanent Differences

Where the conditions stipulated in Paragraph E of Article 9 of the Law are met, a Filing Constituent Entity may make an election to apply the Excess Negative Tax Expense Procedure set out in Article 52 of these Regulations.

In a Fiscal Year in which a Filing Constituent Entity elects to apply the Excess Negative Tax Expense Procedure, the Additional Tax for Permanent Differences shall be deemed to be zero for that Fiscal Year.

The election referred to in Paragraph A of this Article is an Annual Election which can be made in accordance with Article 20 of the Law.