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

Devon Bodoh
Principal, Washington National Tax Corporate Practice
KPMG
He works on corporate tax matters including consolidated returns, domestic and international M&A, and... | Read More
He works on corporate tax matters including consolidated returns, domestic and international M&A, and restructurings, among others. He previously chaired the American Bar Association's Committee on Affiliated and Related Corporations.
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Marcie Barese
Manager
PricewaterhouseCoopers
She is attached to the firm's Washington National Tax Practice Group. Before coming to the firm, she worked with the... | Read More
She is attached to the firm's Washington National Tax Practice Group. Before coming to the firm, she worked with the IRS Office of Associate Chief Counsel (Corporate), where she drafted consolidated return regulations and the unified loss rule.
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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
Her work particularly focuses on application of Subchapter C, but she advises clients on a range of federal income tax issues related to consolidated returns and corporate taxable transactions.
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