Feb

      20

      Affiliated and Related Corporations and Proposed 163(j)

      1 PM EST

      This webinar addresses the application of section 163(j) to affiliated and related corporations.

      Select your state to learn more about the credit details and status of CLE application. Credit is not available for states not listed.

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        01/04/2022

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        02/03/2022

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        02/03/2022

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      $195
      NON-MEMBERS
      $150
      MEMBERS
      $75
      SECTION MEMBERS
      Register Now *Additional discounts may apply at checkout

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      Join and Buy – NOW

      The Treasury Department and the IRS have issued proposed regulations addressing the business interest expense deduction limitation under section 163(j), as amended by the 2017 Tax Act. 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 webinar addresses the application of section 163(j) to affiliated and related corporations. It 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.

      Featured Speakers

      Tonya N. Williams, RSM US LLP, Washington, DC

      Todd B. Reinstein, Pepper Hamilton LLP, Washington, DC

      Cody Forgey, EY, Washington, DC

      Gregory Fairbanks, Grant Thornton LLP, Washington, DC

      PLEASE NOTE: To receive CLE credit, each individual attendee must be logged into the webinar interface for the ENTIRE program (including the Q&A). Partial credit is not available for this program. Please see the CLE Informaton page for more details.

      Registration Fees
      FEES*
      $75 for Section of Taxation Members
      $150 ABA Member*
      $125 Young Lawyers
      $125 Government / Academic / Non-Profit
      $195 All other registrants
      Group Discounts Available: 5 or more: $60 per attendee; 10 or more: $50 per attendee. Please e-mail the tax section (taxlserve@americanbar.org) for group registration.
      FREE Full-time J.D., LL.M., or M.T. Candidates (Law student registrants will also receive membership in the Tax Section.)
      FREE Tax Section Members who are Law Professors
      FREE Press
      *ABA Member registrants will become Tax Section members for 2018-19.
      Fee includes an mp3 audio recording that is available within one week following the program date.
      Law Student registrants, who are current nonmembers, will also receive complimentary membership to the ABA and the Section of Taxation.

      Event Details

      Format

      Web

      Date

      Feb 20, 2019

      2019-02-20T13:00:00-05:00 2019-02-20T14:35:00-05:00 Affiliated and Related Corporations and Proposed 163(j)

      This webinar addresses the application of section 163(j) to affiliated and related corporations.

      Sponsors

      Section of Taxation

      Additional Files & Links

      CLE Information

      The ABA will seek 1.50 CLE credit hours in 60-minute-hour states, and 1.80 credit hours of CLE credit for this program in 50-minute states. Credit hours are estimated and are subject to each state’s approval and credit rounding rules.

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      Registration Information

      For more information on registering for the program, including a copy of the printable registration form, please visit the registration information page.

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