Character of COD Income & Attribute Adjustments under Section 108
Danny Reach will serve as a panelist at this meeting hosted by the American Bar Association (ABA).
This panel will be a deep dive into. some of the more complex areas of the changes in attributes under Section 108 and will also have a special segment on unresolved questions around check-the-box elections for insolvent subsidiaries that are eligible entities.
The panelists will discuss the most pressing questions in this area, including:
- The application of 336 in the context of a check-the-box election on an insolvent subsidiary
- The basics of sourcing COD income
- The character of COD income (e.g. is it Subpart F), which is especially relevant in the brave, new, post-TCJA world
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