See Credit Details Below
Overview
Why You Should Attend
A fundamental understanding of the consolidated return rules is critical for tax professionals who practice in the corporate tax area. This is particularly the case for those involved in mergers and acquisitions, as the consolidated return rules frequently change the otherwise applicable tax consequences of transactions. This year’s program will provide participants with a strong foundation for understanding the primary consolidated return provisions that are frequently encountered in practice. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the fundamentals and key nuances of these rules.
What You Will Learn
After completing this program, participants will be able to:
- Understand basic consolidated return principles
- Make the election to file a consolidated return
- Identify transactions affecting the continuation of a consolidated group
- Allocate basis adjustments to subsidiary stock
- Navigate the special rules for intercompany transactions
- Understand the rules affecting losses on the disposition of subsidiary stock
Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking to gain a better understanding of the nuts and bolts of the consolidated return rules, with a focus on their application to M&A and other transactions.
Program Level: Overview
Intended Audience: Attorneys at law and accounting firms and in-house tax counsel seeking an introduction to the mechanics of the consolidated tax return regulations.
Prerequisites: An interest in exploring the basics of the consolidated tax return regulations.
Advanced Preparation: None
Lecture Topics [Total time 00:08:00]
Segments with an asterisk (*) are available only with the purchase of the entire program.
- Opening Remarks* [00:01:54]
Marie C. Milnes-Vasquez, Bryan P. Collins - Introduction to Consolidated Principles and Definition of Affiliated Group [01:20:22]
Matthew E. Gareau, Marie C. Milnes-Vasquez, Andrew J. Dubroff - Transactions Affecting the Continuation of a Consolidated Group [00:58:16]
Jeffrey L. Vogel, Olivia Ley Orobona, Petya V. Kirilova, Marie C. Milnes-Vasquez - The Investment Adjustment System – Purposes and Application [00:59:51]
Katherine H. Zhang, Gregory A. Fairbanks, Austin Diamond-Jones, Todd B. Reinstein - Consolidated Tax Attributes, Including the Basics of Consolidated Section 382 [01:30:19]
Brian R. Loss, Jonathan I. Forrest, Mark R. Hoffenberg, Bryan P. Collins - Intercompany Transactions, Including TCJA Issues [01:29:05]
Matthew E. Gareau, Jeremy N. Aron-Dine, Brian A. Peabody, Sammy Evei - Overview of Consolidated Return Issues on the Disposition of Stock of Members of a Consolidated Group, Including an Overview of the Unified Loss Rules [01:15:16]
Julie T. Wang, Joseph M. Pari, Bryan P. Collins
The purchase price of this Web Program includes the following articles from the Course Handbook available online:
- Complete Course Handbook
- Overview of Consolidated Groups—Base Requirements for an Affiliated Group and the Privilege to File a Consolidated Return
Gregory Fairbanks - KPMG Alert, Avoiding Late Returns When Corporations Are Acquired by a Consolidated Group (July 11, 2016)
Deanna Harris,Jeffrey Vogel - New York State Bar Association Report on Proposed Section 1502 Regulations Concerning Consolidated Return Basis Adjustments and Related Matters (CO-30-92), Report No. 770 (August 31, 1993)
Todd Reinstein,Austin Diamond-Jones,Katherine Zhang,Gregory Fairbanks - Consolidated Section 382 Rules (February 19, 2021)
Stuart Goldring,Bryan Collins,Mark Hoffenberg - Intercompany Transaction Regulations: An Overview Outline
Brian Peabody,Kristie Withrow,Andrew Dubroff,Matthew Gareau - A Survey of § 1.1502-36 (June 9, 2009)
Don Leatherman
Presentation Material
- Introduction to Consolidated Principles and Definition of an Affiliated Group
Marie C. Milnes-Vasquez, Andrew J. Dubroff, Matthew E. Gareau - Transactions Affecting the Continuation of a Consolidated Group
Marie C. Milnes-Vasquez, Petya V. Kirilova, Olivia Ley Orobona, Jeffrey L. Vogel - The Investment Adjustment System – Purposes and Application
Austin Diamond-Jones, Gregory A. Fairbanks, Todd B. Reinstein, Katherine H. Zhang - Consolidated Tax Attributes, Including the Basics of Consolidated Section 382 and Separate Return Limitation Year Principles
Bryan P. Collins, Jonathan I. Forrest, Mark R. Hoffenberg, Brian R. Loss - Intercompany Transactions
Matthew E. Gareau, Jeremy N. Aron-Dine, Sammy Evei, Brian A. Peabody - Overview of the Unified Loss Rules
Bryan P. Collins, Joseph M. Pari, Julie T. Wang
Why You Should Attend
A fundamental understanding of the consolidated return rules is critical for tax professionals who practice in the corporate tax area. This is particularly the case for those involved in mergers and acquisitions, as the consolidated return rules frequently change the otherwise applicable tax consequences of transactions. This year’s program will provide participants with a strong foundation for understanding the primary consolidated return provisions that are frequently encountered in practice. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the fundamentals and key nuances of these rules.
What You Will Learn
After completing this program, participants will be able to:
- Understand basic consolidated return principles
- Make the election to file a consolidated return
- Identify transactions affecting the continuation of a consolidated group
- Allocate basis adjustments to subsidiary stock
- Navigate the special rules for intercompany transactions
- Understand the rules affecting losses on the disposition of subsidiary stock
Who Should Attend
This course is designed for both private practitioners and in-house tax counsel seeking to gain a better understanding of the nuts and bolts of the consolidated return rules, with a focus on their application to M&A and other transactions.
Program Level: Overview
Intended Audience: Attorneys at law and accounting firms and in-house tax counsel seeking an introduction to the mechanics of the consolidated tax return regulations.
Prerequisites: An interest in exploring the basics of the consolidated tax return regulations.
Advanced Preparation: None