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Consolidated Tax Return Regulations 2013

 February 25, 2013 - February 26, 2013

CLE - Live Seminar


During the past eighteen 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. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the latest developments.
  • 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

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Practising Law Institute
810 Seventh Avenue
New York, New York
United States of America

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