12-Hour Program

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Why You Should Attend

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.

What You Will Learn

  • How the 2017 Tax Act affects and interacts with the rules in the consolidated return regulations
  • 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.

Program Level –

Intended Audience - Attorneys at law and accounting firms and in-house tax counsel seeking a deeper understanding of the mechanics of the consolidated tax return regulations.

Prerequisites – Familiarity with the consolidated tax return regulations.

Advanced Preparation – None

Credit Details