26 C.F.R. § 1.562-3 Distributions by a member of an affiliated group.
Title 26 - Internal Revenue
A personal holding company which files or is required to file a consolidated return with other members of an affiliated group may be required to file a separate personal holding company schedule by reason of the limitations and exceptions provided in section 542(b) and §1.542–4. Section 562(d) provides that in such case the dividends paid deduction shall be allowed to the personal holding company, with respect to a distribution made to any member of the affiliated group, if such distribution would constitute a dividend if it were made to a shareholder which is not a member of the affiliated group.
Title 26: Internal Revenue
PART 1—INCOME TAXES (CONTINUED)
Deduction for Dividends Paid
§ 1.562-3 Distributions by a member of an affiliated group.