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Consolidated Tax Return Regulations 2018

Released on: Feb. 28, 2018
Running Time: 13:12:28

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, including the impact of recently enacted tax reform legislation. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.

 
Lecture Topics [Total RunTime: 13:12:28]
Segments with an asterisk (*) are available only with the purchase of the entire program.

  • Introduction and Opening Remarks* [00:08:10]
    Mark J. Silverman
  • Investment Adjustments and Related Issues [01:44:51]
    Krishna P. Vallabhaneni, William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman
  • Affiliation, Reverse Acquisitions and Accounting Issues [01:32:46]
    Gerald B. Fleming, Kathleen L. Ferrell, Martin Huck, Thomas F. Wessel
  • “Picnic Lunch” Presentation: Current Developments at the Treasury Department [00:54:03]
    Dana L. Trier
  • Intercompany Transactions [02:43:57]
    Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder, Krishna P. Vallabhaneni
  • Acquisition and Separation Issues in Consolidation [01:32:53]
    Robert H. Wellen, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga, Mark J. Silverman
  • Tax Attributes and Consolidation [01:47:22]
    William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen, Gerald B. Fleming
  • Unified Loss Rules [01:32:42]
    Julie T. Wang, Bryan P. Collins, Marc A. Countryman, Michael L. Schler, Lawrence M. Axelrod
  • Consolidated Group Joint Ventures, Including One—Party Limited Liability Companies (LLCs) [01:15:44]
    Robert J. Crnkovich, Craig A. Gerson, Bryan A. Rimmke

The purchase price of this Web Program includes the following articles from the Course Handbook available online:

COMPLETE COURSE HANDBOOK

  • The Consolidated Return Investment Basis Adjustment Rules
    Mark J. Silverman
  • Why Marvel Was Wrongly Decided and Its Impact in Consolidation
    Andrew F. Gordon, Mark J. Silverman
  • The Consolidated Return Investment Basis Adjustment Rules—Study Problems
    Krishna P. Vallabhaneni, Patricia W. Pellervo, Joseph M. Pari, William S. Dixon, Mark J. Silverman
  • Investment Adjustments & Related Issues (February 20, 2018) (PowerPoint slides)
    Patricia W. Pellervo, Joseph M. Pari, Krishna P. Vallabhaneni, William S. Dixon, Mark J. Silverman
  • The Consolidated Group: Continuation and Termination Issues
    Thomas F. Wessel, Jeffrey G. Davis, Jeffrey L. Vogel
  • Group Continuation Rules/Continued Filing Requirement (December 4, 2017) (PowerPoint slides)
    Thomas F. Wessel, Jeffrrey L. Vogel
  • Intercompany Transaction Regulations: An Overview Outline
    Andrew J. Dubroff
  • The Regulations Governing Intercompany Transactions Within Consolidated Groups
    Mark J. Silverman
  • Intercompany Transaction Problems
    Mark J. Silverman
  • Comparison of the Intercompany Obligation Rules Under Former Treas. Reg. § 1.1502-13(g) (1995), Former Prop. Treas. Reg. §1.1502-13(g) (1998), and Treas. Reg. §1.1502-13(g) (2008)
    Mark J. Silverman
  • Current Developments in Tax-Free and Taxable Acquisitions and Separations
    Mark J. Silverman
  • Current Developments in Tax-Free Corporate Reorganizations
    Mark J. Silverman
  • Corporate Divisions Under Section 355
    Lisa M. Zarlenga, Mark J. Silverman
  • The Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute
    Lisa M. Zarlenga, Mark J. Silverman
  • The Fourth Time’s a Charm—Temporary Section 355(e) Regulations Provide Helpful Guidance to Taxpayers
    Mark J. Silverman, Lisa M. Zarlenga
  • Final Section 355(e) Plan Regulations—The Final Chapter in the Saga
    Mark J. Silverman, Lisa M. Zarlenga
  • “Spin-Offs”: The Anti-Morris Trust and Intragroup Spin Provisions
    Mark J. Silverman, Lisa M. Zarlenga
  • Born-to-Die Spinoffs and Convert-Reconvert Transactions
    Andrew F. Gordon
  • Proposed Regs Modify Device and Active Trade or Business Analysis
    Andrew F. Gordon, Mark J. Silverman
  • Spinoffs: Continuing Relationships Between Distributing & Controlled (May 12, 2016)
    Mark J. Silverman, Andrew F. Gordon
  • Recent Developments in the Step Transaction Doctrine
    Mark J. Silverman
  • The Pre-Reorganization Continuity of Interest Regulations
    Mark J. Silverman
  • Continuity of Interest and Continuity of Business Enterprise Regulations
    Mark J. Silverman
  • Assessing the Value of the Proposed “No Net Value” Regulations
    Lisa M. Zarlenga, Gregory N. Kidder, Mark J. Silverman
  • Section 338
    Mark J. Silverman
  • Section 338(h)(10)
    Mark J. Silverman
  • Acquisition and Separation Issues in Consolidation (February 13–14, 2017) (PowerPoint slides)
    Karen Gilbreath Sowell, Robert H. Wellen, Lisa M. Zarlenga, Mark J. Silverman, Eric Solomon
  • Section 382
    Mark J. Silverman
  • The Section 382 Consolidated Return Regulations
    Mark J. Silverman
  • Section 382: Fluctuation in Value
    Mark J. Silverman
  • Consolidated Attribute Reduction Regulations (June 20, 2017)
    Linda Z. Swartz, Stuart J. Goldring
  • Life After the Final Regulations: Consolidated Section 382 and SRLY (June 20, 2017)
    Stuart J. Goldring
  • Application of Cancellation of Debt Rules to Consolidated Group (June 20, 2017) (PowerPoint slides)
    Stuart J. Goldring
  • Acquisitions and Restructurings Involving Troubled Companies (December 7, 2017)
    Mark R. Hoffenberg, William D. Alexander, Bernita L. Thigpen, Stuart J. Goldring
  • The Consolidated Unified Loss Rules
    Mark J. Silverman
  • Consolidated Return Issues for Buyers and Sellers in M&A Transactions (November 2017)
    Michael L. Schler
  • Section 384 of the Internal Revenue Code of 1986
    Mark J. Silverman
  • A New Form of Obscenity? Sorting through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec
    Mark J. Silverman, Gregory N. Kidder
  • The Future of Tax Planning? From Coltec and “You Know It When You See It” to Schering-Plough and “Assimilation with Applicable Tax Laws”
    Amanda P. Varma, Mark J. Silverman
  • Use of Limited Liability Companies in Corporate Transactions
    Mark J. Silverman, Lisa M. Zarlenga

Presentation Material


  • Investment Adjustments & Related Issues
    William S. Dixon, Joseph M. Pari, Patricia W. Pellervo, Mark J. Silverman
  • The Consolidated Return Investment Basis Adjustment Rules - Study Problems
    Mark J. Silverman
  • Group Continuation Rules/Continued Filing Requirement
    Thomas F. Wessel
  • Section 1504 Affiliation Issues
    Kathleen L. Ferrell
  • Section 1504(a)(3): 60-Month Prohibition on Rejoining Consolidated Group
    Martin Huck
  • Intercompany Transactions
    Andrew J. Dubroff, Gordon E. Warnke, Michael J. Wilder
  • Acquisition and Separation Issues in Consolidation
    Mark J. Silverman, Eric Solomon, Karen Gilbreath Sowell, Lisa M. Zarlenga
  • Tax Attributes and Consolidation
    William D. Alexander, Stuart J. Goldring, Mark R. Hoffenberg, Bernita L. Thigpen
  • Unified Loss Rule
    Lawrence M. Axelrod, Bryan P. Collins, Marc A. Countryman, Michael L. Schler
  • Consolidated Group Joint Ventures
    Robert J. Crnkovich, Craig A. Gerson
Chairperson(s)
Mark J. Silverman ~ Steptoe & Johnson LLP
Speaker(s)
William D. Alexander ~ Skadden, Arps, Slate, Meagher & Flom LLP
Lawrence M. Axelrod ~ Ivins, Phillips & Barker Chartered
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 Policy, U.S. Department of the Treasury
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Bernita L. Thigpen ~ KPMG LLP
Dana L. Trier ~ Davis Polk & Wardwell LLP
Krishna P. Vallabhaneni ~ Deputy Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury
Julie T. Wang ~ Senior Counsel to the Associate Chief Counsel (Corporate, Branch 2), Internal Revenue Service
Gordon E. Warnke ~ KPMG LLP
Robert H. Wellen ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Michael J. Wilder ~ McDermott Will & Emery LLP
Lisa M. Zarlenga ~ Steptoe & Johnson LLP
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Related Items

Handbook  Course Handbook Archive

Consolidated Tax Return Regulations 2018  
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