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Insight Center: Events & Webinars

Affiliated and Related Corporations and Proposed 163(j)

Speakers: Todd B. Reinstein, Gregory Fairbanks, Cody Forgey and Tonya M. Williams

2/20/2019
1:00-2:35 PM (ET) | 10:00-11:35 AM (PT)
Affiliated and Related Corporations and Proposed 163(j)

Presented by the American Bar Association Section of Taxation

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. Key topics will include:

  • 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.

Speakers

  • Todd B. Reinstein, Partner, Pepper Hamilton
  • Gregory Fairbanks, Managing Director, Grant Thornton LLP
  • Cody Forgey, Manager, EY
  • Tonya N. Williams, Supervisor, RSM US LLP

CLE credit available.

Registration

ABA Section of Taxation Members: $75
ABA Members: $150
Non-Members: $195

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