Seminar  Program

Consolidated Tax Return Regulations 2018


Select a Location:

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute

New York City Seminar Location

PLI New York Center
, 1177 Avenue of the Americas, (2nd floor), entrance on 45th Street, New York, New York 10036. (800) 260-4754.

New York City Hotel Accommodations

Crowne Plaza Times Square Manhattan, 1605 Broadway (at 48th Street), New York, NY 10019 (212) 977-4000. When calling, mention Practising Law Institute. You can also make reservations online to access PLI's rates.

The Muse, 130 West 46th Street, New York, NY 10036. Please call reservations at 1-800-546-7866. When calling, please mention Practising Law Institute and rate code PLII. You can also Book Online- Kimpton.

Millennium Broadway Hotel, 145 West 44th Street, New York, NY 10036. Please call reservations at 1-800-622-5569. When calling, please mention Practising Law Institute. You can also book online.

Hyatt Times Square, 135 W. 45th Street, New York, NY 10036. For reservations, please call (646) 364-1234. When calling mention rate code CR56218 or Practising Law Institute.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama: PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live seminars qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

California:  PLI’s live seminars qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Illinois: All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Iowa:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Kansas:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Louisiana:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Maine:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Minnesota:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Mississippi:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Missouri:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

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New York State Social Worker Continuing Education (SW CPE):  PLI’s live seminars may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live seminars may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.

PLI’s live and on-demand webcasts are single-user license products intended for an individual registrant only. Credit will be issued only to the individual registered. If two or more individuals wish to participate in a webcast and receive credit, PLI would be happy to provide a Groupcast – group viewing of a webcast. To schedule a Groupcast, please contact PLI at groupcasts@pli.edu.


U.S. MCLE States

Alabama:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live webcasts qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

California:  PLI’s live webcasts qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live webcasts qualify as “eCLE” credit. Attorneys are limited to 12 credits of eCLE per reporting period.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live webcasts qualify as “in-house” credit. Attorneys are limited to 6 in-house credits per reporting period.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live webcasts qualify as “distance education” credit. Attorneys are limited to 9 credits of distance education per reporting period.

Iowa:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Kansas:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Kentucky:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Louisiana:  PLI’s live webcasts qualify as “self-study” credit. Attorneys are limited to 4 credits of self-study per reporting period.

Maine:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

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Mississippi:  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

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Montana:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Nebraska:  PLI’s live webcasts qualify as “computer-based learning” credit. Attorneys are limited to 5 credits of computer-based learning per reporting period.

Nevada:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

New Hampshire:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

New Jersey:  PLI’s live webcasts qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live webcasts can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live webcasts. Skills credits may not be earned via live webcasts.

North Carolina:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

North Dakota:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Ohio:  PLI’s live webcasts qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Oklahoma:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Puerto Rico:  PLI’s live webcasts qualify as “non-traditional” credit. Attorneys are limited to 8 credits of non-traditional programs per reporting period.

Rhode Island:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

South Carolina:  PLI’s live webcasts qualify as “alternatively delivered” credit. Attorneys are limited to 6 credits of alternatively delivered programs per reporting period.

Tennessee:  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 8 credits of distance learning per reporting period.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live webcasts qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live webcasts qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

West Virginia:  PLI’s live webcasts qualify as “online” credit. Attorneys are limited to 12 credits of online instruction per reporting period.

Wisconsin:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Wyoming:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live webcasts qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live webcasts qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live webcasts can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 15 points of distance learning programs per reporting period.

United Kingdom (CPD-UK):  PLI’s live webcasts can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live webcasts may fulfill Australia’s CPD requirements. Credit limits for live webcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Other Credit Types

CPE Credit (NASBA):  PLI’s live webcasts qualify as “Group-Internet-Based” (GIB) credit.

IRS Continuing Education (IRS-CE):  PLI’s live webcasts may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live webcasts may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live webcasts may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live webcasts may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live webcasts qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live webcasts qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live programs.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live webcasts may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live webcasts may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live webcasts may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
New Jersey Groupcast Location

New Jersey Institute for Continuing Legal Education, One Constitution Square, New Brunswick, NJ 08901-1520. 732-249-5100.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “Group-Live delivery” credit.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute

Philadelphia Groupcast Location

Pennsylvania Bar Institute, The CLE Conference Center, Wanamaker Building, 10th floor, Suite 1010, Center City Philadelphia (Juniper St. entrance, between 13th & Broad Sts., opposite City Hall). (800) 932-4637. Click here for directions.

Philadelphia Groupcast Hotel Accommodations

Below is a list of hotel accommodations suggested by the Pennsylvania Bar Institute:

Marriott Residence Inn

Ritz Carlton

Loews Philadelphia

Philadelphia Marriott Downtown

Hilton Garden Inn

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “Group-Live delivery” credit.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute

Pittsburgh Groupcast Location

Pennsylvania Bar Institute, Professional Development Conference Center, 339 Sixth Avenue, Suite 760, Pittsburgh, Pennsylvania 15222-2517. (412) 802-2300. Click Here for Directions

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “Group-Live delivery” credit.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
Cleveland Groupcast Location

The Cleveland Metropolitan Bar Association, 1375 E. 9th Street – Floor 2, Cleveland, Ohio 44114. 216-696-2404.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “Group-Live delivery” credit.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
Atlanta Groupcast Location

Atlanta Bar Association, 400 International Tower, 229 Peachtree Street, NE, Atlanta, GA 30303-1601. (404) 521-0781.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “Group-Live delivery” credit.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

 

Why You Should Attend
During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this area. This program explores the policy and mechanics of these rules and regulations. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

What You Will Learn
• Explore the Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• Study ILM 201726012 and the interaction of the consolidated return regulations and subchapter K
• Consider the impact of the Marvel decision on the investment adjustment rules
• Examine the unified loss rules’ impact on corporations filing consolidated returns, including selling stock of a
   subsidiary member anticipating a loss, and buyers acquiring subsidiary stock from a selling consolidated
   group
• Survey the ways in which the economic substance doctrine affects consolidated returns
• Analyze the interplay between the intercompany transaction provisions and the controlled group rules of
  Section 267(f)
• Explore the ways in which the cancellation of debt (COD) provisions interact with the intercompany
  transaction  rules

Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations and the latest developments in this complex area of the law.


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Day One: 9:00 a.m. - 5:00 p.m.

9:00 Introduction and Opening Remarks
Mark J. Silverman

9:10 Investment Adjustments and Related Issues
Overview of special adjustments to stock basis of subsidiary members of consolidated groups along with detailed examples of more complex situations, including: pitfalls related to excess loss accounts; earnings and profits tier-up rules; special basis and earnings and profits rules related to reverse acquisitions and holding company formations; allocation of items when group members join or depart
Krishna P. Vallabhaneni (Invited) [Deputy Tax Legislative Counsel, Department of the Treasury], William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman

10:55 Networking Break

11:10 Affiliation, Reverse Acquisitions and Accounting Issues
The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including: review of the statutory requirements for affiliation, the application of the 80 percent voting power requirement, the decision in Alumax Inc. v. Comm'r., the effect of bankruptcy proceedings on affiliation, and the impact of the economic substance doctrine of Section 7701(o) on affiliation status; the application of Section 1504(a)(3) to a consolidated group and successor corporations
Gerald B. Fleming (Invited) [Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service], Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury],  Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel

12:40 “Picnic Lunch” Presentation: Current Developments at the Treasury Department
Dana L. Trier (Invited) [Deputy Assistant Secretary, Department of the Treasury]

Please note, credit is not offered for this segment.

Afternoon Session: 2:00 p.m. - 5:00 p.m.

2:00 Intercompany Transactions
Review of the basic rules for taking into account items from intercompany transactions, including the special rules applicable to consolidated group member stock and debt, and issues arising in connection with Section 385; exploration of recent government guidance and trends, practical issues, emphasizing commonly occurring transactions, and practical approaches and possible solutions to dealing with complexity and common "traps for the unwary"
Brett York (Invited) [Attorney-Advisor, Office of Tax Policy, Department of the Treasury], Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder

3:30 Networking Break

3:45 Intercompany Transactions (Continued)

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

9:00 Acquisition and Separation Issues in Consolidation
Recent guidance and transaction trends regarding Section 355 distributions, taxable transactions, and internal restructurings; developments in understanding the scope of the step transaction doctrine; understanding and managing valuable tax attributes
Robert H. Wellen (Invited) [Associate Chief Counsel (Corporate), Internal Revenue Service], Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga

10:30 Networking Break

10:45 Tax Attributes and Consolidation
The complex interaction of the consolidated return regulations with other provisions limiting or otherwise addressing the use of tax attributes including: the effect of Section 382 on separate and consolidated tax attributes, limitations imposed under the separate return limitation (SRLY) rules, and the reduction of consolidated tax attributes resulting from cancellation of indebtedness; common pitfalls to avoid and ameliorative planning techniques will be discussed
Theresa A. Abell (Invited) [Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service], William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen

12:30 Lunch

Afternoon Session: 2:00 – 5:00 p.m.

2:00 Unified Loss Rules
Discussion of disallowance of realized losses (which may or may not be true economic losses), "son of mirror" transactions, loss duplication, attribute reduction, traps for unwary buyers and sellers in M&A transactions, and liquidation of insolvent subsidiaries
Julie T. Wang (Invited) [Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service], Bryan P. Collins, Marc A. Countryman, Michael L. Schler

3:30 Networking Break

3:45 Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs)
Issues arising from the use of disregarded entities and tax partnerships in the transactional setting and within the consolidated group context, including financial distress issues, entity conversion issues, corporate reorganization issues and more
Bryan A. Rimmke (Invited) [Attorney-Advisor, Office of Tax Legislative Counsel, Department of the Treasury], Robert J. Crnkovich, Craig A. Gerson

5:00 Adjourn

Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
Theresa A. Abell ~ Senior Technician Reviewer (Corporate, Branch 1), Internal Revenue Service
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Bryan P. Collins ~ Deloitte Tax LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
Stuart J. Goldring ~ Weil Gotshal & Manges LLP
Mark R. Hoffenberg ~ KPMG LLP
Joseph M. Pari ~ KPMG LLP
Bryan A. Rimmke ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Deputy Assistant Secretary , U.S. Department of the Treasury
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Assistant to the Branch Chief (Corporate, Branch 1), Internal Revenue Service
Gordon E. Warnke ~ Linklaters LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Brett York ~ Attorney-Advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute

Mechanicsburg Groupcast Location

Pennsylvania Bar Institute, 5080 Ritter Rd., Mechanicsburg PA 17055, (800) 932-4637. Click here for directions.

Mechanicsburg Groupcast Hotel Accommodations

Below is a list of hotel accommodations suggested by the Pennsylvania Bar Institute:

Hampton Inn Harrisburg-West, 4950 Ritter Road, Mechanicsburg, Pennsylvania, USA 17055. Tel: 717-691-1300. Fax: 717-691-9692.

Homewood Suites by Hilton® Harrisburg-West Hershey Area, 5001 Ritter Road, Mechanicsburg, Pennsylvania, United States 17055. Tel: 1-717-697-4900. Fax: 1-717-697-9101.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “Group-Live delivery” credit.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

 

Related Items

On-Demand  On-Demand Programs

Consolidated Tax Return Regulations 2017 Feb. 21, 2017

Handbook  Course Handbook Archive

Consolidated Tax Return Regulations 2018  
Consolidated Tax Return Regulations 2017 Mark J Silverman, Steptoe & Johnson LLP
 
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