transcript   Transcript

Consolidated Return Issues under the TCJA

Recorded on: Apr. 23, 2018
Running Time: 00:59:51

Full Transcript:



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Taken from the Web Program Tax Cuts and Jobs Act Update 2018: Issues for U.S. Businesses and Individuals Recorded April 2018 in New York

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Upon the successful completion of this program, the participant will be able to:
  • Recall the impact of the new business interest expense limitations on consolidated groups pursuant to Internal Revenue Code (IRC) §163(j).
  • Recognize the impact the global intangible low-taxed income (GILTI) provisions and the foreign-derived intangible income (FDII) provisions on consolidated groups pursuant to Internal Revenue Code (IRC) §§951A and 250.
  • Describe the impact of the base erosion and anti-abuse tax (BEAT) provisions on consolidated groups pursuant to Internal Revenue Code (IRC) §59A.

Course Overview:
This program will focus on:

  • The impact of the new business interest expense limitations on consolidated groups pursuant to Internal Revenue Code (IRC) §163(j).
  • The impact of the global intangible low-taxed income (GILTI) provisions and the foreign-derived intangible income (FDII) provisions on consolidated groups pursuant to Internal Revenue Code (IRC) §§951A and 250.
  • The impact of the base erosion and anti-abuse tax (BEAT) provisions on consolidated groups pursuant to Internal Revenue Code (IRC) §59A.

CPE Program Level: Update

Intended Audience: CPA’s, tax accountants, tax lawyers, taxpayers, and others seeking the latest information on the impact of Internal Revenue Code (IRC) §163(j)’s new business interest expense limitations, §951A’s global intangible low-taxed income (GILTI) provisions, §250’s foreign-derived intangible income (FDII) provisions, and §59A’s base erosion and anti-abuse tax (BEAT) provisions on consolidated groups.

Prerequisites: A general understanding of the new business interest expense limitations, the global intangible low-taxed income (GILTI) provisions, the foreign-derived intangible income (FDII) provisions, and the base erosion and anti-abuse tax (BEAT) provisions of the Tax Cuts and Jobs Act (TJCA).

Advanced Preparation: None

Instructional Method: QAS Self-Study

Updated: August 2018

Credit Information: 1 CPE credit is available upon completion of this program’s 3 content-review questions and a minimum passing score of 70% on the 5-question final exam. 

Consolidated Return Issues under the TCJA [00:59:51]

• Application of new business interest expense limitations in Section 163(j) to a consolidated group, including allocation to departing members
• Application of new limitations on NOL deductions in Section 172 to a consolidated group
• New international provisions of the TJCA, including the transition tax, global intangible low-taxed income (“GILTI”)/foreign derived intangible income (”FDII”), and base erosion and anti-abuse tax (“BEAT”)
Douglas C. Bates, Bryan P. Collins, Julie A. Divola, Joseph M. Pari

Presentation Material

  • Application of the Global Intangible Low-taxed Income and Foreign-derived Intangible Income Regimes to a Consolidated Group (Handout)
    Bryan P. Collins, Timothy J. Stratford
  • Consolidated Return Issues under the TCJA
    Bryan P. Collins, Julie A. Divola, Joseph M. Pari
  • New Tax Law: International Provisions and Observations
    Joseph M. Pari
    • (s)
      Douglas C. Bates ~ Branch Chief, Office of the Associate Chief Counsel (Corporate, Branch 4), Internal Revenue Service
      Bryan P. Collins ~ Deloitte Tax LLP
      Julie A. Divola ~ Pillsbury Winthrop Shaw Pittman LLP
      Joseph M. Pari ~ KPMG LLP
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