LLM 333

Consolidated Return Regulations

3 Unit(s)

Explores the consolidated tax return regulations, including their conceptual framework, authority and history; eligibility to file; computation of consolidated and separate taxable income; intercompany transactions, attribute limitation rules; consolidated basis adjustments, ELA’s, and the unified loss rules. An emphasis will be placed on how these rules impact acquisition planning. Cross-listed with and equivalent to TA 333. (JD students seeking to enroll must obtain the approval of the program director.) Prerequisite: LLM 322A.