June 9, 2004

The ABA Tax Section’s "Last Wednesday of the Month" Teleconference and Webcast on the Application of Section 108 to Consolidated Groups, postponed on May 26, will be held today at 1:00 – 2:30 pm EST. Here is a description:

The teleconference faculty will review recent temporary regulations under Section 1502 that describe how section 108 applies to consolidated groups. Under section 108, a debtor may exclude cancellation of indebtedness income (COD) from gross income, but it must reduce tax attributes. The temporary regulations primarily describe how a consolidated group reduces tax attributes if a debtor member excludes COD from gross income under section 108. The faculty will provide an overview of the temporary regulations, will discuss proposed regulations concerning the timing of section 108(b) adjustments for consolidated groups, and will consider possible planning options presented by the temporary regulations.

The panelists include Tax Prof Don Leatherman (Tennessee).