Consolidated Group Tax Allocations: Navigating Consolidated Return Rules
Leveraging Allocation Agreements in Acquisitions, Spin-Offs, Issuances of Stock; Implementing New Interagency Guidance for Banks
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE course will provide tax counsel and advisors with the tools necessary to advise business clients that utilize consolidated tax returns. Panelists will review the applicable rules, relevance of consolidated tax allocation agreements in various business situations and address special concerns and updates in the banking industry.
Outline
- Consolidated return tax allocation methods
- Applicability of rules in various business situations
- Acquisitions
- Spin-offs
- Issuances of stock
- Audits
- Refund claims
- Allocation rules in the banking industry
- Unique complexities
- New interagency guidance
- Federal Reserve Act (Sections 23A and 23B)
Benefits
The panel will review these and other key issues:
- What are the rules applicable to tax allocation agreements?
- How are tax rules applied in different business transactions?
- How have tax allocation agreements historically plagued the banking industry? How does the new interagency guidance resolve these issues?
Faculty
Stanley Barsky, Esq.
Cooley
Mr. Barsky's practice focuses on tax. He has authored numerous articles including, Tips on Drafting Tax... | Read More
Mr. Barsky's practice focuses on tax. He has authored numerous articles including, Tips on Drafting Tax Sharing Agreements, Is IRS Pre-Clearance of Accounting Method Changes Really Necessary?, and What Taxpayers Always Want to Know About Accounting Method Changes. He also co-authored Recourse vs. Nonrecourse Liabilities Outside Subchapter K.
CloseKeith Fisher
Of Counsel
Ballard Spahr
Mr. Fisher focuses on financial regulatory work, mergers and acquisitions, and appellate work, especially Supreme Court... | Read More
Mr. Fisher focuses on financial regulatory work, mergers and acquisitions, and appellate work, especially Supreme Court practice. He recently worked as a consultant advising on a variety of ethics, business, and regulatory projects, including federal banking law compliance. He has taught law school courses in banking law, payment systems, anti-money laundering, international banking and finance, and legal ethics. He has substantial experience in U.S. Supreme Court practice, and was the principal author of the American Bar Association's two amicus briefs in Caperton v. A.T. Massey Coal Co., Inc. (2009).
CloseWayne Strasbaugh
Partner
Ballard Spahr
As Practice Leader of the firm’s Tax Group, Mr. Strasbaugh provides tax advice concerning a wide... | Read More
As Practice Leader of the firm’s Tax Group, Mr. Strasbaugh provides tax advice concerning a wide array of areas including, domestic M&As, cross-border corporate acquisitions employing disregarded entities and hybrid entities, spin-off, split-off, and split-up transactions involving the tax-free division of assets held in corporate and noncorporate entities, formation of LPs and LLCs and the drafting of agreements containing workable allocation and distribution provisions, tax-sharing agreements among members of consolidated return groups, and planning for the preservation of net operating losses and other tax benefit attributes.
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