The Thaw continues--attendance at TEI programs returning to pre-recession levels.

Consolidate Returns Seminar

More than 150 tax professionals gathered in Westlake, Texas, on November 18-19, 2010, for TEI's Selected Issues in Consolidated Returns. Sponsored by the Institute's Federal Tax Committee, the seminar offered participants fresh insights into significant developments affecting the taxation of affiliated groups and their members, and helped them refresh their memories about complexities in the thicket of consolidated return rules. From reviewing the requirements for eligibility to join a group and intercompany transactions, to loss limitations, earnings & profits, and investment adjustment rules, the "basics" of consolidated return issues were addressed so that the more advanced issues--such as the "unified" loss rules and acquisitions, dispositions, and separations of group members, and internal group restructuring--would be more accessible. The seminar also explored state and local tax planning and compliance issues for combined and consolidated groups.

Larry Axelrod, a frequent speaker at TEI programs on consolidated returns and now Special Counsel to IRS Associate Chief Counsel (Corporate), spoke at the first day's luncheon. Mr. Axelrod updated the group on current issues affecting corporations and alerted participants to pending guidance on whether a redetermination of intercompany gain or loss is excluded from gross income. Temp. Reg. [section] 1.1502-13T(c)(6)(ii)(C), he said, affords the IRS Commissioner discretion to provide relief in some cases to avoid duplicated gains. The preamble to the temporary rules stated that the IRS is reconsidering the discretionary relief and invited comments on whether the rule should be retained.

Institute President Paul O'Connor characterized attendance at the seminar as "normal" ... for pre-2008, pre-recession programs. "We continue to experience an upturn at TEI programs," he said. "We believe the trend that began in late summer will continue. The key is to deliver high-quality, affordable programs on timely topics. If corporate travel budgets are available, TEI provides the best value for employer training dollars." Mr. O'Connor also expressed his appreciation to Dewey & LeBoeuf for sponsoring the reception and networking...