The panel will focus on recent federal income tax developments important to the operation of US federal consolidated groups. In particular, the presentation will explore the 2024-25 Treasury/IRS business plan, REG-112129-23 (proposed application of CAMT rules in the consolidated group context), REG-105128-23 (proposed dual consolidated loss rules in the consolidated group context), Notice 2024-54 (future proposed rules addressing single-entity treatment for certain subchapter K purposes) and significant non-regulatory developments over the last year.