15 th ANNUAL NORTH CAROLINA/SOUTH CAROLINA/GEORGIA TAX SECTION WORKSHOPS May 27-29, 2016 Kiawah Island Golf Resort Kiawah Island, SC
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1 15 th ANNUAL NORTH CAROLINA/SOUTH CAROLINA/GEORGIA TAX SECTION WORKSHOPS May 27-29, 2016 Kiawah Island Golf Resort Kiawah Island, SC Table of Contents I-A. PROPERTY TAXATION IN GEORGIA Richard C. Litwin Atlanta, GA PROPERTY TAX STRUCTURE IN GEORGIA... I-A-1 What is the Property Tax?... I-A-1 Valuation of Property... I-A-2 Millage Rates and Computation of Tax... I-A-5 PROPERTY TAX EXEMPTIONS... I-A-6 Introduction... I-A-6 Real Property Exempt from Ad Valorem Taxation... I-A-6 Exempt Personal Property... I-A-12 PROCEDURE RETURNS, ASSESSMENTS, APPEALS... I-A-14 Property Tax Returns and Assessment Senate Bill I-A-14 Appeal Options... I-A-15 HOT TOPICS... I-A-17 Two Year Freeze Following Successful Appeal or Agreement... I-A-17 Freeze in Value Following Sale... I-A-18 Georgia s Title Ad Valorem Tax Fee... I-A-22 I-B. NORTH CAROLINA PROPERTY TAX IN 20 MINUTES John A. Cocklereece, Jr. Winston-Salem COVER PAGE... I-B-1 THE MACHINERY ACT IS THE BIBLE... I-B-2 THERE IS LIMITED CASE LAW... I-B-3 WHAT PROPERTY IS TAXABLE... I-B-4 WHO ASSESSES THE PROPERTY?... I-B-8 HOW IS PROPERTY APPRAISED AND ASSESSED?... I-B-9 REAL PROPERTY ASSESSMENT SPECIFICS... I-B-11 BUSINESS PERSONAL PROPERTY ASSESSMENT SPECIFICS... I-B-15 APPEALS... I-B-17 HEARINGS BEFORE THE PTC... I-B-24 RECENT KEY DECISIONS... I-B-28 QUESTIONS... I-B-29 CASES... I-B-31
2 I-C. PROPERTY TAX BASICS AND INCENTIVES Burnet R. Maybank, III Columbia, SC OUTLINE... I-C-1 BASIC PROPERTY TAXES... I-C-2 FEE IN LIEU OF TAX ( FILOT )... I-C-7 MULTI-COUNTY INDUSTRIAL OR BUSINESS PARK ( MCP )/ SPECIAL SOURCE REVENUE CREDIT ( SSRC )... I-C-13 II-A. SOUTH CAROLINA DOR UPDATE Rick Reames III Columbia, SC *Please Note: This is an oral presentation. There are no written materials for this portion of the manuscript. II-B. OVERVIEW OF THE GEORGIA DEPARTMENT OF REVENUE Lynnette T. Lynne Riley Atlanta, GA ATLANTA LOCATIONS...II-B-1 11 REGIONAL OFFICES...II-B-2 RESPONSIBILITIES...II-B-2 TAXPAYER SERVICES DIVISION...II-B-4 AUDIT AND COMPLIANCE DIVISION...II-B-5 THE GEORGIA TAX CENTER...II-B-6 LEGAL AFFAIRS AND TAX POLICY DIVISION...II-B-7 ALCOHOL AND TOBACCO DIVISION...II-B-9 LOCAL GOVERNMENT SERVICES...II-B-12 MOTOR VEHICLES DIVISION...II-B-13 OFFICE OF SPECIAL INVESTIGATIONS...II-B-14 II-C. NORTH CAROLINA TAX UPDATE: LITIGATION AND BEYOND Tenisha S. Jacobs Raleigh III. SUCCESSOR TAX LIABILITY WITH M&A ASSET PURCHASE TRANSACTIONS G.P. Diminich Charleston, SC INTRODUCTION... III-1 WHEN DO TAX LIABILITIES TRANSFER?... III-3 LIABILITY IN EQUITY AS TRANSFEREE... III-4
3 LIABILITY AT LAW... III-8 LIABILITY AT LAW SC/NC/GA LAW... III-13 IV. RECENT DEVELOPMENTS IN THE TAXATION OF SETTLEMENT PAYMENTS Julian A. Fortuna Atlanta, GA INTRODUCTION... IV-1 GENERAL PRINCIPLES... IV-1 PAYMENT BY EMPLOYERS... IV-2 Severance Payments... IV-2 Other Taxable Payments... IV-2 GROSS-UP FOR WITHHOLDING TAXES?... IV-3 NON-TAXABLE SETTLEMENT PAYMENTS... IV-3 Workmen s Compensation for Personal Injuries or Sickness... IV-3 Damages for Physical Injuries, Physical Sickness and Emotional Distress... IV-4 Damages for Wrongful Conviction... IV-5 PUNITIVE DAMAGES... IV-5 Punitive Damages are Generally Taxable... IV-5 Wrongful Death Exception... IV-5 Wrongful Conviction Exception... IV-5 ATTORNEY S FEES AND RELATED COSTS... IV-6 General Rules... IV-6 Information Reporting... IV-6 Tax Deduction Limitations... IV-6 FINES AND PENALTIES... IV-6 General Rules... IV-6 Recent Cases... IV-7 Recent IRS Pronouncements... IV-9 ORDINARY LOSS, CAPITAL LOSS OR CAPITAL COST?... IV-11 General Rules... IV-11 Recent Cases and IRS Pronouncements... IV-12 ORDINARY INCOME, CAPITAL GAIN OR RETURN OF CAPITAL... IV-15 General Rules... IV-15 Recent Cases... IV-15 V. INVESTMENT IN UNITED STATES REAL PROPERTY BY NON-U.S. INVESTORS Richard M. Lipton Chicago, IL COVER PAGE... V-1 GENERAL CONCEPTS... V-2
4 BASIC INVESTMENT STRUCTURES FOR NON-U.S. INVESTORS... V-9 MORE COMPLEX INVESTMENT STRUCTURES FOR NON-U.S. INDIVIDUAL INVESTORS... V-16 VI. IRS COLLECTIONS David M. McCallum Raleigh SCOPE NOTE... VI-1 COLLECTION UPDATES, DEVELOPMENTS, AND THEIR POTENTIAL IMPACT... VI-1 The 2015 IRS Data Book Collection Statistics... VI-1 Offers in Compromise... VI-2 The FAST Act and IRS Collections... VI-6 PATH Act Venue for Appeal of CDP Cases Tried in Tax Court... VI-11 TIGTA Report on Redesigned IRS Collection Notices... VI-12 SYNTHESIS OF RECENT CDP TAX COURT CASES ADDRESSING ASSESSMENT VERIFICATION... VI-14 General Assessment Verification... VI-14 Trust Fund Recovery Penalty Assessment Verification... VI-19 Synthesis... VI-22 PRACTICAL CDP TIPS... VI-23 The Tax Court... VI-23 Standard of Review Applied by the Tax Court... VI-24 Scope of Review... VI-24 Before IRS Appeals... VI-24 Before the Tax Court... VI-30 TEFRA Results and CDP Cases... VI-32 NOMINEE v. ALTER EGO DOCTRINES... VI-34 What Are They?... VI-34 Comparison Nominee v. Alter Ego... VI-39 COMPARISON OF COMPROMISE STANDARDS IN LITIGATED CASES IRS CHIEF COUNSEL v. DOJ TAX DIVISION... VI-40 Brief Background on Division of Work between IRS Chief Counsel and DOJ Tax... VI-40 Evaluation of Collection Potential... VI-40 APPENDICES... VI-43 VII. RECENT DEVELOPMENTS AFFECTING SPIN-OFFS AND OTHER CORPORATE TRANSACTIONS Reginald J. Clark Atlanta, GA NEW RULING POLICIES AND STATUTORY RULES REGARDING SPIN-OFF TRANSACTIONS... VII-1
5 NEW PROPOSED DEBT-EQUITY REGULATIONS... VII-11 VIII. ESOPS Julian A. Fortuna Atlanta, GA Nicholas J. Heinz Memphis, TN W. Dennis Denny Summers Atlanta, GA PART 1 ESOP VALUATION OVERVIEW... VIII-1 TESTING THE FEASIBILITY OF AN ESOP... VIII-1 ESOP APPRAISAL REQUIREMENTS... VIII-2 KEY PRINCIPLES OF ESOP VALUATION... VIII-2 QUALIFICATIONS OF APPRAISER... VIII-4 TYPICAL VALUATION PROCESS... VIII-5 VALUATION METHODOLOGY... VIII-6 REVIEW... VIII-8 PART 2 THE ESOP ALTERNATIVE... VIII-1 BUSINESS OWNERSHIP SUCCESSION THE BIG PICTURE... VIII-1 THE ESOP AS THE LOGICAL BUYER... VIII-2 WHAT IS AN ESOP?... VIII-3 ADVANTAGES OF AN ESOP... VIII-4 CASE STUDY... VIII-7 FREQUENTLY ASKED QUESTIONS... VIII-9 COMPANIES THAT MAY WANT TO CONSIDER AN ESOP... VIII-10 IX. CRIMINAL TAX UPDATE Justin A. Thornton Washington, DC OVERVIEW OF THE FEDERAL TAX ENFORCEMENT SYSTEM... IX-1 General Observations... IX-1 Origins of Criminal Tax Fraud Cases... IX-2 Enforcement Priorities... IX-3 Domestic Investigative Techniques... IX-5 Obtaining Evidence Abroad... IX-5 Conferences, Case Review Procedures, and Prosecutions... IX-7 General Policy Considerations... IX-8 Federal Tax Crimes: Principal Statutes Involved... IX-9 Methods of Proof... IX-14 PRACTICAL CONSIDERATIONS & OBSERVATIONS... IX-15 Early Representation by Defense Counsel: Damage Control... IX-15 Voluntary Disclosures... IX-16 Monitoring the Civil Audit... IX-17 Cooperation or Resistance by the Taxpayer under Investigation... IX-17
6 Accountant s Role in Assisting Defense Counsel... IX-18 Cautionary Checklist for Tax Advisors... IX-18 Federal Sentencing Guidelines... IX-18 CONCLUSION... IX-19 ABA ARTICLE... IX-21
12 th ANNUAL NORTH CAROLINA/SOUTH CAROLINA TAX SECTION WORKSHOPS May 24 26, 2013 Kiawah Island Golf Resort Kiawah Island, SC.
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