Mastering Form 5472: New Filing Requirements for Foreign Individuals, LLCs, and Companies
|
|
- Christiana Small
- 5 years ago
- Views:
Transcription
1 FOR LIVE PROGRAM ONLY Mastering Form 5472: New Filing Requirements for Foreign Individuals, LLCs, and Companies THURSDAY, JULY 27, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is approved for 2 CPE credit hours. To earn credit you must: Participate in the program on your own computer connection (no sharing) if you need to register additional people, please call customer service at x10 (or x10). Strafford accepts American Express, Visa, MasterCard, Discover. Listen on-line via your computer speakers. Respond to five prompts during the program plus a single verification code. You will have to write down only the final verification code on the attestation form, which will be ed to registered attendees. To earn full credit, you must remain connected for the entire program. WHO TO CONTACT DURING THE LIVE EVENT For Additional Registrations: -Call Strafford Customer Service x10 (or x10) For Assistance During the Live Program: -On the web, use the chat box at the bottom left of the screen If you get disconnected during the program, you can simply log in using your original instructions and PIN.
2 Tips for Optimal Quality FOR LIVE PROGRAM ONLY Sound Quality When listening via your computer speakers, please note that the quality of your sound will vary depending on the speed and quality of your internet connection. If the sound quality is not satisfactory, please immediately so we can address the problem.
3 Mastering Form 5472 July 27, 2017 Alison N. Dougherty, J.D., LL.M., Director Aronson, Rockville, Md. Kirsten Burmester, Member Caplin & Drysdale, Washington, D.C.
4 Notice ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY THE SPEAKERS FIRMS TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN. You (and your employees, representatives, or agents) may disclose to any and all persons, without limitation, the tax treatment or tax structure, or both, of any transaction described in the associated materials we provide to you, including, but not limited to, any tax opinions, memoranda, or other tax analyses contained in those materials. The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.
5 Kirsten Burmester 5
6 6038A and 6038C are designed to assist the IRS in its enforcement efforts with respect to U.S. subsidiaries of foreign multinational groups and foreign corporations engaged in a U.S. trade or business Provides the IRS with powerful tools to obtain information about transactions between such taxpayers and related persons by imposing reporting and record maintenance requirements Requirements of 6038A and 6038C Reporting corporation must file a Form 5472 Reporting corporation must maintain records appropriate to determine the correct treatment of transactions with related parties Foreign related party must authorize the reporting corporation to act as its limited agent for purposes of both requests for information and the service of legal process in connection with summonses for the production of documents and testimony under sections 7602 through
7 MASTERING FORM 5472: NEW FILING REQUIREMENTS FOR FOREIGN INDIVIDUALS, LLCS, AND COMPANIES Alison N. Dougherty July 27, partnership-tax-return/ All Rights Reserved 805 King Farm Boulevard Suite 300 Rockville, Maryland P F
8 Form 5472 INFORMATION RETURN OF A 25% FOREIGN-OWNED U.S. CORPORATION OR A FOREIGN CORPORATION ENGAGED IN A U.S. TRADE OR BUSINESS 2015 All Rights Reserved Aronson LLC 8
9 FORM 5472 INFORMATION RETURN OF A 25% FOREIGN-OWNED U.S. CORPORATION OR A FOREIGN CORPORATION ENGAGED IN A U.S. TRADE OR BUSINESS 2015 All Rights Reserved Aronson LLC 9
10 FORM 5472 INFORMATION RETURN OF A 25% FOREIGN-OWNED U.S. CORPORATION OR A FOREIGN CORPORATION ENGAGED IN A U.S. TRADE OR BUSINESS Form 5472 is filed only when there is a reportable transaction between a reporting corporation and any U.S. or foreign related party Reporting corporation = 1. 25% foreign-owned U.S. corporation (by vote or value) 2. Foreign corporation engaged in a U.S. trade or business 2015 All Rights Reserved Aronson LLC
11 FORM 5472 INFORMATION RETURN OF A 25% FOREIGN-OWNED U.S. CORPORATION OR A FOREIGN CORPORATION ENGAGED IN A U.S. TRADE OR BUSINESS 25% Foreign-owned = at least one direct or indirect 25% foreign shareholder at any time during the tax year 25% foreign shareholder = a foreign person that owns directly or indirectly at least 25% of total vote or value of the corporation To determine 25% foreign shareholder and related parties, I.R.C. 318 attribution and constructive ownership rules apply with modification for 10% threshold instead of 50% 2015 All Rights Reserved Aronson LLC
12 FORM 5472 INFORMATION RETURN OF A 25% FOREIGN-OWNED U.S. CORPORATION OR A FOREIGN CORPORATION ENGAGED IN A U.S. TRADE OR BUSINESS Form 5472 is filed only when there is a reportable transaction between a reporting corporation and any U.S. or foreign related party Related party = 1. Any direct or indirect 25% foreign shareholder of the reporting corporation 2. Any person who is related by more than 50% ownership to the reporting corporation 3. Any person who is related by more than 50% ownership to a 25% foreign shareholder of the reporting corporation 4. Any person who is related within the meaning of I.R.C Does not include any corporation filing a U.S. consolidated tax return with the reporting corporation 2015 All Rights Reserved Aronson LLC
13 FORM 5472 INFORMATION RETURN OF A 25% FOREIGN-OWNED U.S. CORPORATION OR A FOREIGN CORPORATION ENGAGED IN A U.S. TRADE OR BUSINESS Form 5472 is filed only when there is a reportable transaction between a reporting corporation and any U.S. or foreign related party Reportable transaction = 1. Any transaction listed on Part IV for which monetary consideration was paid or received during the reporting corporation s tax year 2. Any transaction listed on Part IV for which part of the consideration was non-monetary or less than full consideration was paid or received 2015 All Rights Reserved Aronson LLC
14 FORM 5472 FILING EXCEPTIONS A reporting corporation is not required to file Form 5472 if: 1. It had no reportable transactions 2. A U.S. person in control of a foreign related corporation files Form 5471 for the tax year to report information on Schedule M which shows all reportable transactions between the reporting corporation and the related party (the overlap rule) 3. The related corporation qualifies as a foreign sales corporation for the tax year and files Form 1120-FSC 4. A foreign corporation that otherwise would be required to file does not have a permanent establishment in the United States under an applicable U.S. income tax treaty and timely files Form 8333 Treaty-Based Return Position Disclosure 2015 All Rights Reserved Aronson LLC
15 FORM 5472 FILING EXCEPTIONS A reporting corporation is not required to file Form 5472 if: 5. A foreign corporation whose gross income is exempt from U.S. Federal tax under I.R.C. Section 883 and timely and fully complies with the reporting requirements 6. Both the reporting corporation and the related party are not U.S. persons and the transactions will not generate in any tax year: U.S. source gross income or effectively connected income from a U.S. trade or business, or Any expense, loss or other deduction that is allocable or apportionable to such income 2015 All Rights Reserved Aronson LLC
16 FORM 5472 CONSOLIDATED REPORTING If a reporting corporation is a member of an affiliated group filing a consolidated U.S. Federal income tax return then it can satisfy the requirements by filing a consolidated Form The common parent must attach a schedule stating which members of the U.S. affiliated group are reporting corporations and which of those members are joining in the consolidated Form 5472 filing. The schedule must show the name, address and FEIN of each member who is including transactions on Form A member of an affiliated group is not required to join in the consolidated Form 5472 filing just because other members do All Rights Reserved Aronson LLC
17
18 FORM 5472 PAGE TWO 2015 All Rights Reserved Aronson LLC
19 FORM 5472 REPORTABLE TRANSACTIONS Inventory and tangible property transactions Rents and royalties Sales, leases, licenses, royalties, etc. of intangible property Compensation for different types of services Commissions Amounts loaned and borrowed Interest Premiums Platform contribution transactions Cost sharing transactions Other amounts Part IV lines 1 to 13 report amounts received by the reporting corporation Part IV lines 14 to 26 report amounts paid by the reporting corporation 2015 All Rights Reserved Aronson LLC
20 FORM 5472 REPORTABLE TRANSACTIONS Parts IV and V report monetary, nonmonetary and less than full consideration transactions between the reporting corporation and a foreign related party The terms paid and received include accrued payments and accrued receipts Do not complete Parts IV and V for transactions between the reporting corporation and a U.S. related party Part V Attach a schedule with a description of transaction sufficient to determine the nature and approximate monetary value of the transaction Should include a reasonable estimate of value 2015 All Rights Reserved Aronson LLC
21 FORM 5472 WHEN AND WHERE TO FILE Attach Form 5472 to the reporting corporation s U.S. Federal tax return and file by the due date including extensions For tax years ending after 12/23/2014, Form 5472 cannot be filed separately from U.S. Federal tax return For tax years ending before 12/24/2014, Form 5472 must be filed timely even if U.S. Federal tax return is not filed timely 2015 All Rights Reserved Aronson LLC
22 FORM 5472 PENALTIES $10,000 USD penalty per Form 5472 for the failure to file a substantially complete return or maintain records Additional $10,000 USD penalty per related party for the failure to file for each 30-day period that failure continues after 90 days since notification by IRS Statute of limitations stays open on entire U.S. Federal tax return unless it is possible to establish reasonable cause 2015 All Rights Reserved Aronson LLC
23 FORM 5472 COMMON MISTAKES AND ISSUES Failure to properly classify the categories of intercompany transactions Reporting amounts paid by the reporting corporation on Part IV lines 1 through 13 and amounts received by the reporting corporation on Part IV lines 14 through 26 Failure to report reference IDs for 25% foreign shareholders and foreign related parties without U.S. FEIN Motivating taxpayers to disclose intercompany transactions Motivating foreign persons to disclose identifying information Substantially incomplete forms 2015 All Rights Reserved Aronson LLC
24 FORM 5472 PREPARATION EXAMPLE Forco., Ltd. is a U.K. corporation which wholly owns U.S. Co., Inc. which is a U.S. subsidiary corporation. Forco., Ltd. manufactures widgets which it sells to its U.S. subsidiary corporation U.S. Co., Inc. U.S. Co., Inc. purchases $1,000,000 USD of widgets from its foreign parent corporation Forco., Ltd. U.S. Co., Inc. resells the widgets through its online retail business in the United States. U.S. Co., Inc. also performs market research in the United States for its foreign parent Forco., Ltd. to determine if the U.S. customers are fully satisfied with the quality of the widgets. Forco., Ltd. pays $500,000 USD to its U.S. subsidiary U.S. Co., Inc. as arm s length compensation for the services performed All Rights Reserved Aronson LLC
25 FORM 5472 PREPARATION EXAMPLE 2015 All Rights Reserved Aronson LLC
26 FORM 5472 IRS INFORMATION REQUESTS IRS can request documentation of transactions between a reporting corporation and a foreign related party. If the requested documentation is not provided to the IRS from a foreign person, the IRS is permitted to determine the amount paid for or incurred by the reporting corporation with respect to the transactions at issue based on its own knowledge. The IRS could deny deductions of the reporting corporation due to lack of documentation All Rights Reserved Aronson LLC
27 ALISON N. DOUGHERTY DIRECTOR, TAX SERVICES ARONSON LLC Direct (301) Main (301) King Farm Blvd, Third Floor Rockville, MD Washington, DC Metro Area Alison N. Dougherty provides tax services as a Director at Aronson LLC. Alison specializes in international tax reporting, compliance, consulting, planning and structuring as a subject matter leader of Aronson s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the United States. She has worked extensively in the area of U.S. international tax reporting and compliance with the preparation of the U.S. Federal Forms 5471, 926, 8865, 8858, 5472, 1042, 1042-S, 8621, 8804, 8805, 8813, 8288, 8288-A, 8288-B, 1116, 1118, 1120-F, 1040-NR, 3520, 3520-A, 2555, 5713, 8832, 8833, 8840, 8843, 8854, 8938 and FBAR. She has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization and liquidation of foreign companies. She has significant experience with U.S. Federal nonresident tax withholding, foreign partner tax withholding and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. She often assists U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts. Alison completed the LL.M. (Master of Laws) in Securities and Financial Regulation in 2004 with academic distinction at Georgetown University Law Center. She completed the LL.M. (Master of Laws) in Taxation in 2000 and the Juris Doctor in 1999 at the University of Denver College of Law. She completed a Bachelor of Arts degree in Foreign Language in 1995 at Virginia Commonwealth University All Rights Reserved Aronson LLC
28
29 Kirsten Burmester 29
30 Regulations were promulgated in an effort to combat the perception that the U.S. serves as a tax haven for non-u.s. persons Many jurisdictions, such as Delaware, permit LLCs to register without disclosing their beneficial ownership Prior to the promulgation of the regulations, DREs had no federal tax reporting requirements The U.S. has reciprocal exchange of information obligations under its FATCA IGAs but, prior to the promulgation of the new regulations, had no mechanism for gathering the information necessary to comply with such obligations 30
31 New regulations add provisions to Treas. Reg that classify a DRE as a corporation for purposes of section 6038A if The entity is a domestic entity; and One foreign person has direct or indirect sole ownership of the entity Indirect sole ownership means ownership by one person entirely through one or more DREs or grantor trusts The taxable year of a DRE treated as a corporation under the new regulations is The same as the taxable year of foreign owner if that person has a U.S. income tax or information return filing obligation for its taxable year; or If the foreign owner has no U.S. filing obligation, the calendar year 31
32 DREs classified as corporations for purposes of section 6038A must file a Form 5472 Regulatory exceptions to the 6038A record-keeping requirements and requirement to act as an agent for related parties for small corporations and corporations with de minimis related party transactions do not apply to DREs Regulatory exception for reporting related corporations that qualify as foreign sales corporations filing Form 1120-FSC does not apply to DREs 32
33 Solely for DREs, the new regulations expand the definition of reportable foreign related party transactions to include any transaction defined by section (i)(7) Includes amounts paid or received in connection with the formation, dissolution, acquisition and dispositions of the DRE Includes contributions to and distributions from the DRE Examples clarify that the following transactions must be reported: Contributions to a domestic DRE from is foreign owner and distributions from a domestic DRE to its foreign owner Transactions between tiers of DREs with a single ultimate foreign owner are reportable related-party transactions 33
34 New regulations apply to tax years of reporting DREs beginning after December 31, 2016, and ending on or after December 13, 2017 Commissioner is delegated the authority to prescribe the time and manner of filing of the Form 5472 for DREs Form has yet to be updated 34
35 Kirsten Burmester 35
36 $10,000 penalty for each year a reporting corporation fails to file Form 5472 Substantially incomplete filing constitutes a failure to file $10,000 penalty for each year and each related party with respect to which the reporting corporation fails to keep records If IRS mails a notice of failure to the reporting corporation and the corporation does not remedy the failure within 90 days, there is an additional $10,000 penalty for each 30 days or fraction thereof during which the failure continues No cap on this penalty Criminal penalties under section 7203 for willful failure to file and under 7206 for filing a false or fraudulent return Note that the IRS also has broad discretion to determine the income tax consequences of related party transactions where there is a failure of foreign related party to authorize the reporting corporation as an agent or the reporting corporation fails to respond to summonses 36
37 Penalties for failure to file Form 5472 and maintain records may be excused upon a showing that the taxpayer acted reasonably and in good faith Good faith standard is defined in 6038A regulations Reporting corporation must make an affirmative showing of facts supporting reasonable cause in a written declaration under penalties of perjury Honest misunderstanding of fact and law that is reasonable in light of the experience and knowledge of taxpayer Reasonable reliance on professional Reasonable cause is deemed not to exist after the date on which the IRS mails notice of failure to file or maintain records 37
38 Reasonable cause standard applied liberally for small corporations (<$20 million gross receipts) if: Corporation has no knowledge of the 6038A; Has limited presence in and contact with the United States; and Promptly complies with all requests to file 5472 and furnish records Accrual of penalties for continued failure to file after notice has been mailed will stop if reporting corporation files Form 5472, furnishes information necessary to complete the Form 5472, or, in the case of failure to maintain records, demonstrates compliance with maintenance of records for the taxable year in which the examination occurs and subsequent years to the satisfaction of the District Director 38
39 Kirsten Burmester Member, Caplin & Drysdale, Chartered Disclaimer This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome. Attorney Advertising It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation Caplin & Drysdale, Chartered All Rights Reserved. 39
Form 8858 Reporting of U.S. Owned Foreign Disregarded Entities: Ownership and Correct Filing Status
Form 8858 Reporting of U.S. Owned Foreign Disregarded Entities: Ownership and Correct Filing Status FOR LIVE PROGRAM ONLY TUESDAY, JANUARY 9, 2018 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationInternational Tax Impact of Business Entity Selection for Foreign Operations of U.S. Companies
FOR LIVE PROGRAM ONLY International Tax Impact of Business Entity Selection for Foreign Operations of U.S. Companies TUESDAY, DECEMBER 12, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationForm 8865 Reporting of Foreign Partnership Income and Navigating Rules for Allocable Share of Foreign Income
FOR LIVE PROGRAM ONLY Form 8865 Reporting of Foreign Partnership Income and Navigating Rules for Allocable Share of Foreign Income THURSDAY, AUGUST 3, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationMastering Foreign Tax Credits for Corporations and Individuals: Calculations, Carrybacks, Carryforwards and Limitations
Mastering Foreign Tax Credits for Corporations and Individuals: Calculations, Carrybacks, Carryforwards and Limitations FOR LIVE PROGRAM ONLY WEDNESDAY, SEPTEMBER 7, 2016, 1:00-2:50 pm Eastern IMPORTANT
More informationForm 926 Compliance: Domestic Corporate Transfers to Foreign Subsidiaries and Related Corporations
FOR LIVE PROGRAM ONLY Form 926 Compliance: Domestic Corporate Transfers to Foreign Subsidiaries and Related Corporations THURSDAY, SEPTEMBER 7, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationForm 926 Reporting Transfers to Foreign Corporations: Avoiding Harsh Penalties
Form 926 Reporting Transfers to Foreign Corporations: Avoiding Harsh Penalties Ensuring Consistency Between FATCA, FBAR, Form 5471 and Other Foreign Asset Forms TUESDAY, AUGUST 30, 2016, 1:00-2:50 pm Eastern
More informationMastering Form 5471 for Interests in Foreign Entities: Determining Ownership Share and Correct Filing Status
Mastering Form 5471 for Interests in Foreign Entities: Determining Ownership Share and Correct Filing Status TUESDAY, JUNE 23, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved
More informationIncome Tax Treaty Interpretation and Practice for Tax Professionals: Claiming and Reporting Tax Treaty Positions for Individuals
Income Tax Treaty Interpretation and Practice for Tax Professionals: Claiming and Reporting Tax Treaty Positions for Individuals TUESDAY, OCTOBER 27, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This
More informationMastering Form 5471 for Interests in Foreign Entities: Determining Ownership Share and Correct Filing Status
Mastering Form 5471 for Interests in Foreign Entities: Determining Ownership Share and Correct Filing Status TUESDAY, FEBRUARY 10, 2015, 1:00-2:50 PM EASTERN IMPORTANT INFORMATION This program is approved
More informationMultistate Allocation of Trust Distributable Net Income: Income Sourcing and Apportionment
Multistate Allocation of Trust Distributable Net Income: Income Sourcing and Apportionment THURSDAY, FEBRUARY 21, 2019, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is approved
More informationNew Accounting Method Rules for Small Business Taxpayers Under IRC 448
FOR LIVE PROGRAM ONLY New Accounting Method Rules for Small Business Taxpayers Under IRC 448 THURSDAY, FEBRUARY 7, 2019, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is
More informationCheck-the-Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment Through Entity Selection
Check-the-Box Elections for Foreign Subsidiaries: FOR LIVE PROGRAM ONLY Achieving Optimal Tax Treatment Through Entity Selection THURSDAY, OCTOBER 20, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationMastering U.S. Tax Reporting of Foreign Retirement Account Ownership and Distributions
FOR LIVE PROGRAM ONLY Mastering U.S. Tax Reporting of Foreign Retirement Account Ownership and Distributions THURSDAY, JULY 6, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This
More informationBasis Calculations in Section 368 Reorganizations: Tax Deferral Benefits For Subsidiary Shareholders
FOR LIVE PROGRAM ONLY Basis Calculations in Section 368 Reorganizations: Tax Deferral Benefits For Subsidiary Shareholders THURSDAY, DECEMBER 14, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationTax Reporting and Reconciliation of Hedge Fund and Other Alternative Investment Fund K-1s
FOR LIVE PROGRAM ONLY Tax Reporting and Reconciliation of Hedge Fund and Other Alternative Investment Fund K-1s Navigating Footnotes and Tying Information to the Tax Return THURSDAY, MAY 19, 2016, 1:00-2:50
More informationFinal Section 385 Regs: Navigating State and Local Tax Impact of New Debt-to-Equity Reclassification Rules
FOR LIVE PROGRAM ONLY Final Section 385 Regs: Navigating State and Local Tax Impact of New Debt-to-Equity Reclassification Rules THURSDAY, JANUARY 12, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationIMPORTANT INFORMATION FOR THE LIVE PROGRAM
FOR LIVE PROGRAM ONLY Form 8621 PFIC Reporting: Navigating the Highly Complex IRS Passive Foreign Investment Company Rules Determining Which Assets Require PFIC Reporting, Calculating Tax and Interest,
More informationIMPORTANT INFORMATION
UDFI for Exempt Organizations: Reporting Unrelated Debt-Financed Income on Form 990-T Avoiding Costly Allocation Mistakes in the Sale of Encumbered Property WEDNESDAY, FEBRUARY 3, 2016, 1:00-2:50 pm Eastern
More informationOpting Out of PFIC Tax-and-Interest Treatment: Making QEF Elections on Form 8621 Part II
FOR LIVE PROGRAM ONLY Opting Out of PFIC Tax-and-Interest Treatment: Making QEF Elections on Form 8621 Part II TUESDAY, OCTOBER 17, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationIRC 751 "Hot Assets": Calculating and Reporting Ordinary Income in Disposition of Partnership or LLC Interests
IRC 751 "Hot Assets": Calculating and Reporting Ordinary Income in Disposition of Partnership or LLC Interests THURSDAY, JULY 9, 2015, 1:00-2:50 pm Eastern This program is approved for 2 CPE credit hours.
More informationRepatriation Tax Planning: Inbound Asset Transfers, Cash Dividends and Other Strategies for Tax Professionals
Repatriation Tax Planning: Inbound Asset Transfers, Cash Dividends and Other Strategies for Tax Professionals FOR LIVE PROGRAM ONLY TUESDAY, OCTOBER 30, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationOpting Out of PFIC Tax-and-Interest Treatment: Making QEF Elections on Form 8621 Part II
FOR LIVE PROGRAM ONLY Opting Out of PFIC Tax-and-Interest Treatment: Making QEF Elections on Form 8621 Part II THURSDAY, OCTOBER 20, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationIMPORTANT INFORMATION FOR THE LIVE PROGRAM
Mastering U.S. Permanent Establishment Tax Under New OECD Guidance vs. General Tax Treaty Approach Navigating Income Attribution Rules in the U.S. Model Income Tax Convention and Recently Signed Tax Treaties
More informationNew IRC 864(c)(8) Withholding Rules on Partnership Sales: Calculations and Affidavit of Exemption
New IRC 864(c)(8) Withholding Rules on Partnership Sales: Calculations and Affidavit of Exemption FOR LIVE PROGRAM ONLY TUESDAY, JULY 31, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationAlternative Investments for Nonprofits and Exempt Organizations: Avoiding Unforeseen Tax Consequences
FOR LIVE PROGRAM ONLY Alternative Investments for Nonprofits and Exempt Organizations: Avoiding Unforeseen Tax Consequences TUESDAY, DECEMBER 12, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationSubpart F Income Rules and Sections 956, 958 and 1248: Meeting the Reporting Challenges of Controlled Foreign Corporations
FOR LIVE PROGRAM ONLY Subpart F Income Rules and Sections 956, 958 and 1248: Meeting the Reporting Challenges of Controlled Foreign Corporations THURSDAY, JULY 21, 2016, 1:00-2:50 pm Eastern IMPORTANT
More informationForm 8621 PFIC Reporting: Navigating the Complex IRS Passive Foreign Investment Company Rules
Form 8621 PFIC Reporting: Navigating the Complex IRS Passive Foreign Investment Company Rules FOR LIVE PROGRAM ONLY THURSDAY, JANUARY 18, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationIMPORTANT INFORMATION FOR THE LIVE PROGRAM
Reporting UBTI and UBIT in Partnerships and S Corporations: Mastering K-1 Disclosures for Exempt Org Partners Key Box 20V Reporting, Footnotes and Separate Disclosures, and UDFI Exemptions THURSDAY, SEPTEMBER
More informationIMPORTANT INFORMATION FOR THE LIVE PROGRAM
FOR LIVE PROGRAM ONLY Partnership Terminations: Mastering Section 708 Filing Short Year Returns, Revisiting Elections, Amortization Opportunities, Basis Adjustments and More WEDNESDAY, JANUARY 25, 2017,
More informationForm 5471 Substantial Compliance Rules: New IRS International Practice Unit Guidance
Presenting a live 90-minute webinar with interactive Q&A Form 5471 Substantial Compliance Rules: New IRS International Practice Unit Guidance When Will the IRS Deem An International Tax Information Filing
More informationGILTI Calculations for Individual CFC Shareholders: New Section 951A Tax on Foreign Intangible Income
GILTI Calculations for Individual CFC Shareholders: New Section 951A Tax on Foreign Intangible Income FOR LIVE PROGRAM ONLY TUESDAY, MAY 22, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationNew IRC 987 Regs and Foreign Currency Translation: Income Calculation for Qualified Business Units
FOR LIVE PROGRAM ONLY New IRC 987 Regs and Foreign Currency Translation: Income Calculation for Qualified Business Units THURSDAY, NOVEMBER 30, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationForm 1041 Schedule D: Reporting Capital Gains for Trusts and Estates
Form 1041 Schedule D: Reporting Capital Gains for Trusts and Estates FOR LIVE PROGRAM ONLY THURSDAY, SEPTEMBER 13, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is
More informationForm 4720 Private Foundation Excise Tax Return: Reporting Taxable Violations
FOR LIVE PROGRAM ONLY Form 4720 Private Foundation Excise Tax Return: Reporting Taxable Violations THURSDAY, JULY 12, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program
More informationSection 1202 Qualified Small Business Stock: Maximizing Tax Advantages of Gain Exclusion and Deferral
Section 1202 Qualified Small Business Stock: Maximizing Tax Advantages of Gain Exclusion and Deferral THURSDAY, AUGUST 27, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for
More informationIMPORTANT INFORMATION FOR THE LIVE PROGRAM
U.S.-Canadian Dual Taxation Pitfalls: Reporting Issues and Planning Opportunities for U.S. Taxpayers Navigating Tax Treaties to Minimize Tax on Passive Income and Pass-Through Income THURSDAY, APRIL 27,
More informationS Corporation Stock Sales: Mastering Tax Reporting, Income/Loss Allocation and Section 1377 Elections
FOR LIVE PROGRAM ONLY S Corporation Stock Sales: Mastering Tax Reporting, Income/Loss Allocation and Section 1377 Elections WEDNESDAY, FEBRUARY 15, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationShort Year 1065 Returns for Terminated Partnerships: Avoiding Penalties For Failure to Report
FOR LIVE PROGRAM ONLY Short Year 1065 Returns for Terminated Partnerships: Avoiding Penalties For Failure to Report WEDNESDAY, NOVEMBER 8, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationTax Reform and U.S. Foreign Reporting for Individuals: New Cross-Border Repatriation and Inclusion Provisions
Tax Reform and U.S. Foreign Reporting for Individuals: FOR LIVE PROGRAM ONLY New Cross-Border Repatriation and Inclusion Provisions THURSDAY, FEBRUARY 15, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationComposite Returns and Nonresident Withholding for Pass-Through Entities: Navigating the Multistate Complexities
Composite Returns and Nonresident Withholding for Pass-Through Entities: Navigating the Multistate Complexities Determining Whether to File Composite Returns, Dealing With Withholding Requirements FOR
More informationIC-DISC Compliance: Exporter Challenges in the Federal Tax Break
FOR LIVE PROGRAM ONLY IC-DISC Compliance: Exporter Challenges in the Federal Tax Break THURSDAY, DECEMBER 21, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is approved
More informationSection 962 Election of The Corporate Tax Rate by Individuals For Global Intangible Low-Taxed Income ( GILTI) And Subpart F Income Inclusions
Section 962 Election of The Corporate Tax Rate by Individuals For Global Intangible Low-Taxed Income ( GILTI) And Subpart F Income Inclusions TUESDAY, JULY 10, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationTax Reporting and Reconciliation of Hedge Fund and Other Alternative Investment Fund K-1s
Tax Reporting and Reconciliation of Hedge Fund and Other Alternative Investment Fund K-1s Navigating Footnotes and Tying Information to the Tax Return MAY 21, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationTax Planning and Reporting for Partnership Equity Compensation Grants
Tax Planning and Reporting for Partnership Equity Compensation Grants FOR LIVE PROGRAM ONLY WEDNESDAY, MAY 30, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is approved
More informationForm 3115 Change in Accounting Method: Navigating the IRS Repair Regulations
FOR LIVE PROGRAM ONLY Form 3115 Change in Accounting Method: Navigating the IRS Repair Regulations WEDNESDAY, MAY 4, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is
More informationIRC 751 "Hot Assets": Calculating and Reporting Ordinary Income in Disposition of Partnership or LLC Interests
FOR LIVE PROGRAM ONLY IRC 751 "Hot Assets": Calculating and Reporting Ordinary Income in Disposition of Partnership or LLC Interests WEDNESDAY, JULY 26, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationTax and Accounting Implications Following a Partner's Death: Financial and Operational Considerations
Tax and Accounting Implications Following a Partner's Death: Financial and Operational Considerations TUESDAY, FEBRUARY 9, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for
More informationNew Guidance on Calculating UBTI for Separate Trades or Businesses Under Tax Reform
New Guidance on Calculating UBTI for Separate Trades or Businesses Under Tax Reform FOR LIVE PROGRAM ONLY THURSDAY, NOVEMBER 29, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This
More informationReverse 704(c) Allocations: Partnership Revaluations, Triggering Events, and Recent IRS Guidance
Reverse 704(c) Allocations: Partnership Revaluations, Triggering Events, and Recent IRS Guidance FOR LIVE PROGRAM ONLY WEDNESDAY, JANUARY 10, 2018 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationIRC Section 734 Adjustments: Applying the 754 Election to Distributions of Partnership Property
FOR LIVE PROGRAM ONLY IRC Adjustments: Applying the 754 Election to Distributions of Partnership Property THURSDAY, AUGUST 10, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This
More informationForm 4970 and Form 1041 Schedule J Accumulation Tax: Reporting Distributions From Foreign Trusts
Form 4970 and Form 1041 Schedule J Accumulation Tax: Reporting Distributions From Foreign Trusts FOR LIVE PROGRAM ONLY THURSDAY, JANUARY 11, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationSection 1291 Excess Distribution Calculations for PFIC Tax and Interest Reporting
Section 1291 Excess Distribution Calculations for PFIC Tax and Interest Reporting FOR LIVE PROGRAM ONLY TUESDAY, JUNE 19, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program
More informationForm 1041 Compliance for Special Needs Trusts: First-Party vs. Third-Party, Qualified Disability Trusts
Form 1041 Compliance for Special Needs Trusts: First-Party vs. Third-Party, Qualified Disability Trusts FOR LIVE PROGRAM ONLY TUESDAY, NOVEMBER 13, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationIMPORTANT INFORMATION FOR THE LIVE PROGRAM
U.K.-Based Retirement Accounts for U.S. Taxpayers: Mastering Reporting, Maximizing Planning Opportunities Utilizing Treaty Provisions to Achieve Optimal Tax Results While Complying With Foreign Reporting
More informationForm 5227 Reporting: Charitable Split-Interest Trusts, NIIT Calculations, and More
Form 5227 Reporting: Charitable Split-Interest Trusts, NIIT Calculations, and More THURSDAY, AUGUST 20, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for 2 CPE credit hours.
More informationInformation Reporting and Civil Penalties (in a Nutshell)
I. In General Information Reporting and Civil Penalties (in a Nutshell) By Lucy S. Lee, Esq. Caplin & Drysdale, Chartered Washington, D.C. 2008 Lucy S. Lee The Internal Revenue Code (the Code ) 1 generally
More informationMastering 1099-B Reporting on Schedule D and Form 8949: Meeting Capital Gains Basis Reporting Challenges
FOR LIVE PROGRAM ONLY Mastering 1099-B Reporting on Schedule D and Form 8949: Meeting Capital Gains Basis Reporting Challenges TUESDAY, AUGUST 1, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationReporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies
FOR LIVE PROGRAM ONLY Reporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies WEDNESDAY, JULY 13, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationCanadian RRSPs, RRIFs and Other Foreign Funded Retirement Plans: Tax Planning and Reporting for 402(b) and Other Funded Plans
Canadian RRSPs, RRIFs and Other Foreign Funded Retirement Plans: Tax Planning and Reporting for 402(b) and Other Funded Plans TUESDAY, MAY 1, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationNavigating Section 988 Foreign Currency Transaction Reporting Rules for Options, Straddles and Hedges
Navigating Section 988 Foreign Currency Transaction Reporting Rules for Options, Straddles and Hedges Navigating Section 988 Foreign Currency Transaction Reporting Rules for Options, Straddles and Hedges
More informationIRC 645 Elections for Qualified Revocable Trusts: Mastering the DNI Separate Share Calculation Rules
FOR LIVE PROGRAM ONLY IRC 645 Elections for Qualified Revocable Trusts: Mastering the DNI Separate Share Calculation Rules THURSDAY, JUNE 8, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More information401k Annual Audits: Anticipating Serious and Costly Errors, Evaluating Alternative Solutions
FOR LIVE PROGRAM ONLY 401k Annual Audits: Anticipating Serious and Costly Errors, Evaluating Alternative Solutions TUESDAY, APRIL 11, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationMastering Reporting of Publicly Traded Partnership and MLP K-1s on Partners' Returns Navigating MLP K-1 Footnotes and Tying Information to the 1040
Mastering Reporting of Publicly Traded Partnership and MLP K-1s on Partners' Returns Navigating MLP K-1 Footnotes and Tying Information to the 1040 WEDNESDAY, JANUARY 18, 2017, 1:00-2:50 pm Eastern IMPORTANT
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Nonresident Alien Tax Compliance: Challenges and Planning Techniques for Tax Professionals Recent IRS Compliance Campaign, ECI vs. FDAP Income,
More informationMastering Reporting of Publicly Traded Partnership and MLP K-1s on Partners' Returns
Mastering Reporting of Publicly Traded Partnership and MLP K-1s on Partners' Returns FOR LIVE PROGRAM ONLY TUESDAY, JANUARY 23, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This
More informationNew IRC Section 67(g) and Form 1041 Trust Deduction Rules Post-Tax Reform
New IRC Section 67(g) and Form 1041 Trust Deduction Rules Post-Tax Reform FOR LIVE PROGRAM ONLY TUESDAY, MAY 22, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is approved
More informationMastering the Rules of S Corporation Shareholder-Employee Compensation
FOR LIVE PROGRAM ONLY Mastering the Rules of S Corporation Shareholder-Employee Compensation WEDNESDAY, JANUARY 31, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is
More informationNew U.S. Reporting Requirements for Foreign- Owned Disregarded Entities
New U.S. Reporting Requirements for Foreign- Owned Disregarded Entities Presented to STEP Miami Carlos A. Somoza and Maria Toledo Kaufman Rossin January 26, 2017 Agenda Reporting under IRC Section 6038A
More informationGST and Form 709: Fundamentals of Generation-Skipping Transfer Tax Reporting
GST and Form 709: Fundamentals of Generation-Skipping Transfer Tax Reporting FOR LIVE PROGRAM ONLY THURSDAY, DECEMBER 20, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program
More informationMastering the Effectively Connected Income Rules for Foreign Persons Engaged in Inbound Transactions
Mastering the Effectively Connected Income Rules for Foreign Persons Engaged in Inbound Transactions TUESDAY, SEPTEMBER 22, 2015 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for
More informationReconciling GAAP Basis and Tax Basis in Partnership Income Tax Returns and K-1 Schedules
Reconciling GAAP Basis and Tax Basis in Partnership Income Tax Returns and K-1 Schedules FOR LIVE PROGRAM ONLY WEDNESDAY, JULY 25, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationState Income Tax Treatment of Nonresident Trusts: Compliance Challenges and Planning Opportunities
State Income Tax Treatment of Nonresident Trusts: Compliance Challenges and Planning Opportunities FOR LIVE PROGRAM ONLY TUESDAY, JULY 24, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationSales and Use Tax Reserves: Reconciling ASC 450/FAS 5 Reserve Requirements With IAS 37 Standard for Foreign Activities
Sales and Use Tax Reserves: Reconciling ASC 450/FAS 5 Reserve Requirements With IAS 37 Standard for Foreign Activities THURSDAY, APRIL 6, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationComposite Returns and Nonresident Withholding for Pass-Through Entities: Navigating the Multistate Complexities
FOR LIVE PROGRAM ONLY Composite Returns and Nonresident Withholding for Pass-Through Entities: Navigating the Multistate Complexities TUESDAY, MAY 1, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationIC-DISC Strategies: Mastering the Complex Operational Challenges
IC-DISC Strategies: Mastering the Complex Operational Challenges Anticipating IRS Audit Risks, Calculating Commissions, and Tackling Computational Intricacies TUESDAY, MAY 6, 2014, 1:00-3:00 pm Eastern
More informationPresenting a 90-minute encore presentation featuring live Q&A. Today s faculty features:
Presenting a 90-minute encore presentation featuring live Q&A New Section 199A: Deductions, Limitations, Complexities and Opportunities for Pass-Through Entities Determining Qualified Business Income,
More informationSection 704, Targeted Allocations, and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance
Section 704, Targeted Allocations, and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance Understanding the Economic Effect Test and How to Allocate Income or Loss Using Targeted Allocations
More informationState Sales Tax on Drop Shipments: Navigating Various States' Rules on Registrations and Exemptions
Navigating Various States' Rules on Registrations and Exemptions THURSDAY, JUNE 25, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for 2 CPE credit hours. To earn credit you
More informationSection 704, Targeted Allocations and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance
Section 704, Targeted Allocations and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance WEDNESDAY, SEPTEMBER 2, 2015, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved
More informationFinal IRS Sect. 67(e) Regs for Estate and Trust Taxpayers: Applying the Required 2% Deduction Floor
Final IRS Sect. 67(e) Regs for Estate and Trust Taxpayers: Applying the Required 2% Deduction Floor WEDNESDAY, OCTOBER 15, 2014, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for
More informationPrivate Investment Funds and Tax Reform
Presenting a live 90-minute webinar with interactive Q&A Private Investment Funds and Tax Reform Carried Interest, QBI and Interest Deductions, Sale of Partnership Interests, Computation of UBTI, and More
More informationAllocating Capital Gains to Distributable Net Income in Estates and Trusts: Achieving Optimal Tax Treatment
Allocating Capital Gains to Distributable Net Income in Estates and Trusts: Achieving Optimal Tax Treatment FOR LIVE PROGRAM ONLY TUESDAY, FEBRUARY 13, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationS-Corporations Owning Multiple Entities: Mastering Tax Reporting and Planning Opportunities
FOR LIVE PROGRAM ONLY S-Corporations Owning Multiple Entities: Mastering Tax Reporting and Planning Opportunities TUESDAY, MAY 10, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationMastering Form 5500 Schedule H: Avoiding Audit Triggers
FOR LIVE PROGRAM ONLY Mastering Form 5500 Schedule H: Avoiding Audit Triggers Financial Information Reporting Requirements, Identifying Valuation Challenges and Expanded Compliance Questions THURSDAY,
More informationForm 8903: Domestic Production Activities Deduction for Pass-Thrus and Other Business Entities
Form 8903: Domestic Production Activities Deduction for Pass-Thrus and Other Business Entities Mastering Complex Determinations, Calculations and Reporting Challenges for the DPAD WEDNESDAY, FEBRUARY 25,
More informationForm 1040NR for Foreign Trusts: Income Tax Reporting for Foreign Non-Grantor Trusts
FOR LIVE PROGRAM ONLY Form 1040NR for Foreign Trusts: Income Tax Reporting for Foreign Non-Grantor Trusts WEDNESDAY, JULY 19, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This
More informationMastering IRC 2632 GST Exemption Allocation Rules: Identifying GST Trusts and Indirect Skips
FOR LIVE PROGRAM ONLY Mastering IRC 2632 GST Exemption Allocation Rules: Identifying GST Trusts and Indirect Skips THURSDAY, JUNE 22, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationUK-Based Retirement Accounts for U.S. Taxpayers: Mastering Reporting, Maximizing Planning Opportunities
UK-Based Retirement Accounts for U.S. Taxpayers: FOR LIVE PROGRAM ONLY Mastering Reporting, Maximizing Planning Opportunities TUESDAY, FEBRUARY 6, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationMastering U.S. Tax Reporting of Foreign Retirement Account Ownership and Distributions
FOR LIVE PROGRAM ONLY Mastering U.S. Tax Reporting of Foreign Retirement Account Ownership and Distributions THURSDAY, FEBRUARY 9, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationSection 704(c): Contributions of Appreciated or Depreciated Property to Partnerships and LLCs
Section 704(c): Contributions of Appreciated or Depreciated Property to Partnerships and LLCs Navigating Complex Allocation Rules, Curative and Remedial Allocations, Elections, and Anti-Abuse Rules THURSDAY,
More informationNew FASB ASU Revenue Recognition Standards for Nonprofit Entities: Implementing ASC 606 for NFPs
New FASB ASU 2014-09 Revenue Recognition Standards for Nonprofit Entities: Implementing ASC 606 for NFPs FOR LIVE PROGRAM ONLY TUESDAY, MAY 22, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationIRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Entities for Tax Arbitrage
Presenting a live 90-minute webinar with interactive Q&A IRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Entities for Tax Arbitrage Lowering U.S. Income Tax on Income
More informationExecutive Compensation: Tax and Other Considerations for Restricted Stock Awards
Presenting a live 90-minute webinar with interactive Q&A Executive Compensation: Tax and Other Considerations for Restricted Stock Awards Strategies for Navigating Substantial Risk of Forfeiture Analysis,
More informationMastering FATCA Compliance and Implementation for NFFEs: Are You Ready for the July 1 Deadline?
Mastering FATCA Compliance and Implementation for NFFEs: Are You Ready for the July 1 Deadline? TUESDAY, JUNE 24, 2014, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for 2 CPE credit
More informationLeveraging Earnings-Stripping Regs for Foreign Investments: Maximizing Tax Savings, Minimizing IRS Scrutiny
Presenting a live 110-minute teleconference with interactive Q&A Leveraging Earnings-Stripping Regs for Foreign Investments: Maximizing Tax Savings, Minimizing IRS Scrutiny THURSDAY, FEBRUARY 6, 2014 1pm
More informationNew FASB ASU on Not-For-Profit Financial Reporting and Disclosures: Are You Ready?
FOR LIVE PROGRAM ONLY New FASB ASU 2016-14 on Not-For-Profit Financial Reporting and Disclosures: Are You Ready? TUESDAY, MARCH 7, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
More informationMastering Form 990 Schedule A: Protecting Public Charity Status, IRC 509 Public Support Test Calculations and Reporting
FOR LIVE PROGRAM ONLY Mastering Form 990 Schedule A: Protecting Public Charity Status, IRC 509 Public Support Test Calculations and Reporting TUESDAY, OCTOBER 17, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
More informationTax Reporting of Bitcoin and Other Cryptocurrency: Calculating Basis, Income and Gain
Tax Reporting of Bitcoin and Other Cryptocurrency: Calculating Basis, Income and Gain FOR LIVE PROGRAM ONLY TUESDAY, JUNE 26, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This
More informationStructuring Leveraged Loans After Tax Reform: Concerns for Multinational Entities
Presenting a live 90-minute webinar with interactive Q&A : Concerns for Multinational Entities Section 956 Deemed Dividend Rules, Limits on Interest Deductions, Tax Distributions, Corporate vs. Pass-Through
More informationNew Section 199A: Structuring Real Estate Transactions to Take Advantage of the Qualified Business Income Deduction
Presenting a 90-minute encore presentation featuring live Q&A New Section 199A: Structuring Real Estate Transactions to Take Advantage of the Qualified Business Income Deduction THURSDAY, JANUARY 17, 2019
More information