Federal Consolidated Return Regulations for Corporate Taxpayers: Mastering Complex Rules and Guidance

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

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Conducted on Thursday, April 2, 2015

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Course Materials

This course will prepare corporate tax professionals to fully comply 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 intercompany stock gains.

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, disaffiliation and other issues relevant to combined groups.

Even without recent regulatory changes and private letter rulings, understanding the 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. 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. 382 issues
    5. Impact of current environment
    6. Debt restructurings
    7. Worthless stock deductions
    8. Other relevant law changes
  2. Consolidated return regs and guidance
  3. Key consolidated return regulatory sections that offer ongoing compliance challenges
    1. Investment adjustments
    2. Joining or leaving a consolidated return group ("end of day rule")
    3. Consolidated group joint ventures
    4. Experiences and examples from past and current filings and audits
    5. Best practices for return preparation
    6. Common mistakes and pitfalls in completing combined returns


The panel will address these and other key issues:

  • Understanding recent changes, including laws, regulations and IRS guidance such as the recently issued proposed regulations (REG-1000400-14, published March 6, 2015) on the "end-of day rule" and PLRs on application of consolidated Sect. 382
  • Analysis of key sections of consolidated return regulations that offer ongoing problems for corporate taxpayers
  • Lessons from return filing and federal audit of consolidated returns
  • Coping with unified loss rules in an environment of increased losses


Featherman, Greg
Greg W. Featherman

Mr. Featherman advises KPMG partners, employees and clients on corporate tax matters including domestic and...  |  Read More

Olivia Ley
Olivia Ley

Ms. Ley is a Director in the National Tax Office of PricewaterhouseCoopers, LLP’s Mergers & Acquisitions...  |  Read More

Wayne Strasbaugh
Wayne Strasbaugh

Ballard Spahr

As Practice Leader of the firm’s Tax Group, Mr. Strasbaugh provides tax advice concerning a wide...  |  Read More

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