• Simulcast - PLI

PLI - Consolidated Tax Return Regulations 2020

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TypeTitleStartEndCLEPrice
Mechanicsburg
PBI Conference Center
5080 Ritter Road, Rossmoyne Exit, Rt. 15, Mechanicsburg PA, 17055
STARTTue., Jan. 21, 2020
9:00 AM
ENDWed., Jan. 22, 2020
5:00 PM
CLE 12 sub/0 eth PRICE $1,895.00
Philadelphia
The CLE Conference Center
Wanamaker Building, 10th Floor, Suite 1010, Philadelphia PA, 19107
STARTTue., Jan. 21, 2020
9:00 AM
ENDWed., Jan. 22, 2020
5:00 PM
CLE 12 sub/0 eth PRICE $1,895.00
Pittsburgh
PBI Professional Development Center
Heinz 57 Center, 339 Sixth Avenue, 7th Fl., Pittsburgh PA, 15222
STARTTue., Jan. 21, 2020
9:00 AM
ENDWed., Jan. 22, 2020
5:00 PM
CLE 12 sub/0 eth PRICE $1,895.00

About

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
Practice Areas

Faculty

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