Affiliated and Related Corporations and the Proposed Sec. 163(j) Regulations (On-Demand CLE)

    Affiliated and Related Corporations and the Proposed Sec. 163(j) Regulations (On-Demand CLE)
    CLE 90 min

    Affiliated and Related Corporations and the Proposed Sec. 163(j) Regulations (On-Demand CLE)

    If you have clients who are taxpayers with significant business interest expense, you'll need to understand the proposed regulations issued by the Treasury Department and the IRS, which address the business interest expense deduction limitation under section 163(j), as amended by the 2017 Tax Act. This program addresses the application of section 163(j) to affiliated and related corporations and its complexities so you can better serve your clients' needs.

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      02/03/2022

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      02/03/2022

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      1.50 credit hours

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      01/04/2022

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      02/03/2021

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      1.50 credit hours

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      01/04/2022

    1.50 total credit hours including

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      1.50 credit hours

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      01/04/2022

    1.50 total credit hours including

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      02/03/2022

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      12/31/2019

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      12/31/2019

    1.80 total credit hours including

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      12/31/2019

    1.50 total credit hours including

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      02/04/2020

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      02/03/2022

    1.80 total credit hours including

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      02/03/2022

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      01/04/2022

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      02/03/2021

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      02/03/2022

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      03/04/2022

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      02/03/2021

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      1.50 credit hours

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      01/04/2022

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    • General

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      Approved

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      01/04/2022

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    • General

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      Self apply

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      12/31/2019

    1.50 total credit hours including

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      Applied for

      1.50 credit hours

      Available until:

      02/03/2022

    1.50 total credit hours including

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      Approved

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      Available until:

      01/31/2020

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      02/03/2022

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      Available until:

      02/03/2022

    1.80 total credit hours including

    • General

      Status:

      Approved

      1.80 credit hours

      Available until:

      02/03/2022

    1.50 total credit hours including

    • General

      Status:

      Self apply

      1.50 credit hours

      Available until:

      01/04/2022

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    A wide range of taxpayers and their U.S. businesses are now subject to the rules under section 163(j) and its effects are far-reaching. Taxpayers with significant business interest expense will want to consider these rules when engaging in merger and acquisition activity, making borrowings, planning internal restructurings, reporting financial results, and preparing tax returns.

    Although the limitation formula appears simple, its application as set out in the statute and the proposed regulations thereunder is very complex. Many of the rules apply differently to different entity types, even to and within a group of affiliated and related corporations. Adding to the complexity are the questions that remain unaddressed and the new questions raised by the published guidance.

    This program will cover:

    • General applicability of section 163(j), as amended
    • An overview of the proposed regulations
    • Mechanics of calculating consolidated ATI and the section163(j) limit
    • Absorption and use of 163(j) limitation (Five Step Process)
    • SRLY
    • The interplay of section 163(j) and section 382
    • Other consolidated group considerations, including member departures, investment adjustments, partnership items and dispositions, unified loss rules, section 381 transactions, and transition year rules

    Product Details

    Panelists

    Cody Forgey, Gregory Alan Fairbanks, Todd Bennett Reinstein, Tonya Williams

    Sponsors

    Section of Taxation

    Product Code

    CETX1901W3OLC

    Duration

    90

    Publication Date

    2/20/2019 12:00:00 AM

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