RAMCO filed as a consolidated group for years because of the advantages based on the tax attributes of the member companies. The economic conditions for RAMCO started to change. Currently, all members of the consolidated group are generating income whereas previously some members generated income and others losses. The shareholders of the consolidated group have been approached by outside individuals interested in purchasing some of the member companies of RAMCO. If the sale occurs, the group will no longer be eligible to file as a consolidated group.

The shareholders have approached you for advice. Using your tax research tools available, conduct research to determine the tax planning strategies you would offer the shareholders and what should be considered before proceeding with the sale.

Please complete at least one page of research on the topic and include a minimum of two references.

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