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Overview
During the past twenty-seven years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with recent 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.
Topics Include:
• How tax reform affects and interacts with the rules in the consolidated return regulations
• The Third Circuit decision in Duquesne Light Holdings and the Ilfeld doctrine
• ILM 201726012 and the interaction of the consolidated return regulations and Subchapter K
• The impact of the Marvel decision on the investment adjustment rules
• 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
• The ways in which the economic substance doctrine affects consolidated returns
• The interplay between the intercompany transaction provisions and the controlled group rules of Section 267(f)
• The ways in which the cancellation of debt (COD) provisions interact with the intercompany transaction rules