Federal Consolidated Return Regulations for Corporate Taxpayers

Mastering Complex Rules and Guidance to Ensure Ongoing Compliance

Recording of a 110-minute CPE/CLE webinar with Q&A

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Conducted on Thursday, May 19, 2011

Recorded event now available

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Course Materials

This teleconference will prepare corporate tax professionals to comply fully with the federal consolidated return rules and provide a thorough update on recent statutory and regulatory changes. The panel will offer lessons based on filing experiences and outline best practices to ensure compliance now and in the future.


Significant amendments to federal consolidated return regulations for corporate income tax continue to create compliance challenges for tax staffs of large, complex companies. Those challenges include the treatment of inter-company stock gains and five-year NOL carryback elections.

Attention to recent IRS rulings and guidance is crucial to mastering the complexities, but some issues remain confusing. Tax specialists continue to grapple with consolidated Sect. 382 matters, NOL usage, discharge of debt income, and other issues relevant to combined groups.

Even without recent regulatory changes and private letter rulings, mastering vast regulatory demands of the consolidated return rules is an ongoing battle. Lessons from experienced peers and advisory professionals can make the difference between an accurate return and costly mistakes.

Listen as our panel of experienced advisors and corporate tax professionals provides updates on recent regulations and guidance and outlines best practices for sharpening consolidated return compliance on an ongoing basis.



  1. 2009 changes to federal law that affect planning for consolidated returns
    1. NOL carryforward changes
    2. Discharge-of-indebtedness income changes
    3. M&A transaction changes
    4. Sect. 383 issues
    5. Impact of current environment
      1. Debt restructurings
      2. Worthless stock deductions
    6. Other relevant law changes
  2. Consolidated return regs and guidance of last few months
    1. T.D. 9515 reg changes on treatment of certain inter-company gains from stock owned by group members
    2. PLRs dealing with Notice 2003-65 in consolidation and application of Sect. 382(l)(5)/(6) in consolidation
    3. Consolidated return issues in latest updates to IRS priority guidance plan
    4. Other relevant IDRs
  3. Key consolidated return regulatory sections that offer ongoing compliance challenges
    1. Investment adjustments
    2. Affiliations and reverse acquisitions
    3. Intercompany transactions
    4. Consolidation issues (acquisitions and separations)
    5. Loss disallowances
    6. Consolidated group joint ventures
  4. Experiences and examples from past and current filings and audits
    1. Best practices for return preparation
    2. Common mistakes and pitfalls in completing combined returns


The panel will give you practical solutions for complying with the consolidated return regs, including:

  • Understanding recent changes, including laws, regulations and IRS guidance such as the T.D. 9515 reg changes on inter-company gains from stock held by group members and PLRs on application of consolidated Sect. 382.
  • Analysis of key sections of consolidated return regulations that offer ongoing problems for corporate taxpayers.
  • Lessons learned from return filing and federal audit of consolidated returns.
  • Coping with unified loss rules in an environment of increased losses.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Devon Bodoh
Devon Bodoh
Principal, Washington National Tax Corporate Practice

He works on corporate tax matters including consolidated returns, domestic and international M&A, and...  |  Read More

Marcie Barese
Marcie Barese

She is attached to the firm's Washington National Tax Practice Group. Before coming to the firm, she worked with the...  |  Read More

Michelle Albert
Michelle Albert
Senior Manager, Transaction Advisory Services - Tax
Ernst & Young

Her work particularly focuses on application of Subchapter C, but she advises clients on a range of federal income tax...  |  Read More

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