Final Section 385 Regs: Navigating State and Local Tax Impact of New Debt-to-Equity Reclassification Rules
|
|
- Michael Kennedy
- 5 years ago
- Views:
Transcription
1 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 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 Final Section 385 Regs Jan. 12, 2017 Jaye A. Calhoun, Partner Kean Miller, New Orleans Kelley C. Miller, Attorney Reed Smith, 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 What Do We Do About Intercompanies? State Treatment of Related Party Transactions
6 Existing State Approaches to Taxing Unitary (?) Businesses Combined reporting Transfer pricing adjustments (482-Style Provisions) Related-company addback provisions State-specific common law distinguishing debt and equity Absence of uniformity creates opportunity/issues 6 Reed Smith LLP Kean Miller LLP
7 Existing State Approaches Combined Reporting Mandatory in 25 states and DC 7 Reed Smith LLP Kean Miller LLP
8 Existing State Approaches - Combined Reporting cont d. Transactions between members of filing group generally eliminated Doesn t reach transactions with entities outside the filing group, including: o Entities not part of unitary business o Entities outside U.S. (water s edge elections) o Other entities not included in combined filings (e.g. insurance companies, financial institutions, RICs, and REITs) o Tax Haven Modifications for WE States 8 Reed Smith LLP Kean Miller LLP
9 Existing State Approaches - Combined Reporting cont d. Pros: States believe Combination addresses tax minimization strategies States believe separate reporting causes revenue loss Consider state studies Consider shift to passthroughs as choice of entity Principle appeals to scholars 9 Reed Smith LLP Kean Miller LLP
10 Existing State Approaches - Combined Reporting cont d. Cons: o May not address tax minimization strategies o Always winners/losers either way o What s wrong with tax minimization anyway if its legal o Lots of controversy regarding what unitary means and what businesses are unitary o May distort instate income (Constitutional issues) o Compliance costs o Lack of uniformity creates potential for multiple taxation of same income 10 Reed Smith LLP Kean Miller LLP
11 Existing State Approaches-Transfer Pricing Adjustments Unclear that all separate-filing states have authority to adjust intercompany pricing o Does adoption of federal taxable income starting point include an implied adoption of IRC 482? o Has the state enacted its own transfer-pricing adjustment statute? (e.g. MA G.L. c. 63, 39A) Most states lack transfer pricing expertise at the audit level o MTC program (State Intercompany Transactions Advisory Service SITAS) 11 Reed Smith LLP Kean Miller LLP
12 Existing State Approaches-Interest Addback Adopted in 9 states and the District of Columbia Additional states (including PA) have addback limited to relatedcompany interest related to intangibles 12 Reed Smith LLP Kean Miller LLP
13
14 Existing State Approaches- Interest Addback cont d. Not designed to distinguish between true debt and other intercompany arrangements o Addback exceptions only applicable after true debt determination e.g. Staples, Inc. v. Commissioner, MA ATB Docket Nos. C and C (2015) Typical exceptions include payments to payees subject to tax in another state/country, payees in treaty countries, payments where addback would be unreasonable, etc. o Factors demonstrating true debt (e.g. written note, arms-length interest) may contribute toward showing that addback would be unreasonable Addback (denying interest deduction) does not address whether obligation was debt or equity for non-income-based taxes or equity ownership tests (combined reporting, dividends received deductions, reorganizations, etc.) 14 Reed Smith LLP Kean Miller LLP
15 Existing State Approaches-State- Specific Common Law Based on federal common law Alterman Foods, Inc. v. U.S., 505 F.2d 873 (5 th Cir. 1974) Massachusetts Examples o NY Times Sales, Inc. v. Commissioner, 667 N.E.2d 3012 (Mass. App. Ct. 1996) o Overnite Transportation Co. v. Commissioner, 764 N.E. 2d (Mass. App. Ct. 2002) o National Grid Holdings, Inc. v. Commissioner, Mass. App. Ct. Docket No. 14-P-1662 (2016) May still be relevant despite enactment of combined reporting e.g. are intercompany obligations liabilities for purposes of state taxes based on net worth Common law not effected by new federal regulations 15 Reed Smith LLP Kean Miller LLP
16 Existing State Approaches- LA as an example 16 Reed Smith LLP Kean Miller LLP
17 Act 16 (HB 55) Intercompany Expense Addback Requires that certain deductible interest expenses, intangible expenses, and management fees be added-back when computing corporation income tax liability by enacting La. R.S. 47: Requires corporations to add-back otherwise deductible items, specifically: Interest expenses and costs Intangible expenses and costs Management fees Directly or indirectly paid, accrued, or incurred to or with one or more related members Unless certain safe harbors apply Effective for all tax years beginning on or after January 1, Reed Smith LLP Kean Miller LLP
18 Act 16 (HB 55) Intercompany Expense Addback Safe harbors include: Subject to Tax Exception - If the corresponding item of income was in the same taxable year either subject to a tax based on or measured by the related member's net income in Louisiana or any other state, or was subject to a tax based on or measured by the related member's net income by a foreign nation which has an enforceable income tax treaty with the United States, if the recipient was a "resident" as defined in the income tax treaty with the foreign nation; or Substantial Business Purpose Exception - the transaction giving rise to the interest expenses and costs, the intangible expenses and costs, or the management fees between the corporation and the related member did not have as a principal purpose the avoidance of any Louisiana tax. Conduit Exception - If the transaction giving rise to the interest expenses and costs, intangible expenses and costs, or the management fees has a substantial business purpose and economic substance and contains terms and conditions comparable to a similar arm's length transaction between unrelated parties, the transaction shall be presumed to not have as its principal purpose tax avoidance, subject to rebuttal by the Secretary of the Department of Revenue. 18 Reed Smith LLP Kean Miller LLP
19 Act 16 (HB 55) Intercompany Expense Addback LDR has issued Notice of Intent re: reg LAC 61:I.1115 Adopts very broad definitions Terms defined include: interest expenses, intangible expenses, intangible property, and management fees Requires contemporaneous documentation for the business purpose exception Provides that [m]ere statements or assertions that a transaction was intended to allow for better management or greater utilization of intangible assets, or similarly unsubstantiated claims are not sufficient to establish a principal non-tax business purpose. Imposes a debt over asset percentage test for some interest expense deductions Compares intercompany debt to asset ratio to third party debt to asset ratio Requires a written statement with the return for exceptions Hearing date was 11/30/16 19 Reed Smith LLP Kean Miller LLP
20 The New Federal Regulations State Conformity in General Conformity likely o States that start tax computation with federal taxable income as computed under the current Internal Revenue Code either as filed (e.g. IL) or on a separate company basis (e.g. NJ and PA) Conformity unclear o Fixed-date conformity states (e.g. AZ -1/1/2016 and VA -12/31/2015) Does fixed-date conformity matter when IRC 385 was enacted in 1969? o States that adopt specific IRC sections (e.g. CA although CA generally adopts subchapter C as of the latest conformity date 1/1/2015) o States may not necessarily follow all Treas. Regs. (e.g. CA FTB takes position that it can opt out of Treas. Regs.) 20 Reed Smith LLP Kean Miller LLP
21
22 The New Federal Regulations Documentation Application at State Level Federal exemption for debt between members of the same consolidated group Unclear exemption has any application in states that don t conform to the federal consolidated return rules Separate analysis required for state purposes for debt covered by consolidated group exception for federal purposes States will likely limit exception to obligations between members of the same the state combined filing unit Documentation rules only applicable to expanded groups that are: o o o o Publicly traded; Have total assets in excess of $100M; or Have total revenue in excess of $50M for financial statement purposes Will states apply these limitations on a separate company basis? 22 Reed Smith LLP Kean Miller LLP
23 The New Federal Regulations Documentation Implications Complying with documentation rules for state purposes will likely be a major compliance burden o Consider application to typical cash pooling / cash management practices Lack of documentation could be used to recharacterize intercompany obligations that otherwise would be treated as debt under common law Silver Lining?: Compliance with documentation requirement should help with classification under common law 23 Reed Smith LLP Kean Miller LLP
24 The New Federal Regulations Recharacterization One Corporation Exception Federal exemption for debt between members of the same consolidated group won t be applicable in most states o Exemption likely limited to obligations between corporations included in the state combined filing group o Thus, exception likely will not apply to obligations between a corporation and expanded group members non-unitary corporations 80/20 companies captive insurance companies, etc. 24 Reed Smith LLP Kean Miller LLP
25 The New Federal Regulations Recharacterization Other Exceptions cont d. Exception for qualified short-term debt instruments o Intended to cover typical cash management / cash pooling arrangements State rules requiring imputation of interest on intercompany debt (e.g. NJ) may throw obligations out of exception for interest-free loans Exception for obligations to extent of expanded group earnings account o Unclear how this will apply at state level where there is no expanded group concept May be limited to distributing corporation s E&P in separate filing states 25 Reed Smith LLP Kean Miller LLP
26 The New Federal Regulations Recharacterization Other Exceptions cont d. Exceptions for corporations with special federal income tax treatment o S corporations Application unclear in states allowing separate state S election or opt out from federal election- e.g. NJ, NY and PA Also unclear in states that do not follow federal S treatment e.g. IL o REITs o RICs o Regulated financial companies and certain non-captive insurance companies 26 Reed Smith LLP Kean Miller LLP
27 The New Federal Regulations Recharacterization State Consequences Consequences for payors o Interest (deductible) and return of principal recharacterized as dividend (nondeductible) and return of capital Consequences for payees o Interest (income) and return of principal recharacterized as dividends (offset by partial or full DRD) and return of capital and gain o Apportionment Interest (typically included in receipts factor) re-characterized as dividends (typically excluded from receipts factor) 27 Reed Smith LLP Kean Miller LLP
28 The New Federal Regulations Recharacterization State Consequences cont d. Recharacterization may o change composition of state combined filing unit o create differences in state and federal stock basis o generate a deferred intercompany stock account ( DISA ) in CA or WV o impact satisfaction of ownership / control thresholds for legal entity reorganizations at state level Re-characterization may also impact computation of: o Franchise taxes based on net worth reported for federal income tax purposes (not GAAP) o Gross receipts taxes Are dividends included in gross receipts? Are dividends sourced in the same manner as interest? o NH Business Enterprise Tax based in part on dividends 28 Reed Smith LLP Kean Miller LLP
29 The New Federal Regulations Other Implications Interplay with state related- company interest addback provisions o Is addback superfluous with issuance of debtequity rules? o Is addback per se unreasonable if an obligation is classified as debt State-specific common law (e.g. MA) not superseded 29 Reed Smith LLP Kean Miller LLP
30 Questions? Jaye Calhoun Kean Miller LLP 909 Poydras Street, Suite 3600 New Orleans, Louisiana (direct) (facsimile) Kelley C. Miller Reed Smith LLP 2500 One Liberty Place 1650 Market Street Philadelphia, PA (direct) (facsimile) 30 Reed Smith LLP Kean Miller LLP
Composite 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 informationMastering Form 5472: New Filing Requirements for Foreign Individuals, LLCs, and Companies
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
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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 informationThe State of Debt Under the Proposed Section 385 Regulations
Robb Chase Andrew Appleby TEI Denver May 11, 2016 The State of Debt Under the Proposed Section 385 Regulations All Rights Reserved. This communication is for general informational purposes only and is
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 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 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 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 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 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 informationMandatory Unitary Combined Reporting: Navigating Conflicting and Evolving State Rules
FOR LIVE PROGRAM ONLY Mandatory Unitary Combined Reporting: Navigating Conflicting and Evolving State Rules THURSDAY, SEPTEMBER 29, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
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 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 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 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 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 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 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 informationMultistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners
FOR LIVE PROGRAM ONLY Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners THURSDAY, OCTOBER 19, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE 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 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 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 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 informationAdd-Back Statutes: Where Do We Go From Here?
2005 SEATA Conference July 12, 2005 Add-Back Statutes: Where Do We Go From Here? Presented By: Joe Garrett, Esq. Alabama Department of Revenue & Kelly W. Smith, CPA, Esq. PricewaterhouseCoopers LLP 0 Related
More informationDistributable Net Income: Mastering Difficult DNI Calculations for Estates and Complex Trusts
FOR LIVE PROGRAM ONLY Distributable Net Income: Mastering Difficult DNI Calculations for Estates and Complex Trusts TUESDAY, DECEMBER 5, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM
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 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 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 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 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 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 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 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 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 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 informationHold the Intercompany Transactions State and Local Tax Considerations
Hold the Intercompany Transactions State and Local Tax Considerations Current Issues in State & Local Taxation TEI Philadelphia Chapter February 22, 2017 Open Weaver Banks Andrew Appleby 2017 (US) LLP
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 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 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 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 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 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 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 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 Tax Implications of New (and Pending) Federal Rules
Todd A. Lard Andrew D. Appleby NESTOA September 27, 2016 State Tax Implications of New (and Pending) Federal Rules All Rights Reserved. This communication is for general informational purposes only and
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 informationIRC Sect. 704(b): Partnership Allocations
IRC Sect. 704(b): Partnership Allocations Navigating Complex Rules to Determine Valid Allocation of Income, Gain, Loss, Deductions or Credits THURSDAY, OCTOBER 3, 2013, 1:00-2:50 pm Eastern IMPORTANT INFORMATION
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 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 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 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 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 informationPresenting a live 110-minute teleconference with interactive Q&A. Today s faculty features:
Presenting a live 110-minute teleconference with interactive Q&A State Corporate Income Apportionment Key Fundamentals Understanding Trends and State Approaches to Factor Weighting, Service Revenue, Joyce
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 informationMastering Form 8937 and Section 6045B:
Presenting a live 110 minute teleconference with interactive Q&A Mastering Form 8937 and Section 6045B: An Ongoing Obligation Complying With Reporting Requirements Arising From Activities Affecting Tax
More informationThe 2019 National Multistate Tax Symposium State tax reboot The age of Multistate. February 6-8, 2019
The 2019 National Multistate Tax Symposium State tax reboot The age of Multistate February 6-8, 2019 State treatment of federal Tax Cuts and Jobs Act s foreign income and GILTI Susan Courson-Smith, Pfizer
More informationIRC 751 "Hot Asset" Treatment: New Rules for Calculating Ordinary Income Recharacterization
Presenting a live 90-minute webinar with interactive Q&A IRC 751 "Hot Asset" Treatment: New Rules for Calculating Ordinary Income Recharacterization New IRS Proposal on Determining Partners' Share of Section
More informationTEI Tax School Louisiana Update May 11, 2018
TEI Tax School 2018 Louisiana Update May 11, 2018 Introductions to LA and LDR How Louisiana Got to Now Economics and displacement of Hurricane Katrina Louisiana Dixiecrats turn red in 2010 Presidential
More informationStructuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences
Presenting a live 90-minute webinar with interactive Q&A Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences TUESDAY,
More informationCalculating Trust Fiduciary Accounting Income: Interpreting Operating Documents, Applying UPIA and State Law
Calculating Trust Fiduciary Accounting Income: Interpreting Operating Documents, Applying UPIA and State Law FOR LIVE PROGRAM ONLY OCTOBER 18, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE
More informationForm 1120S Challenges for Enrolled Agents: Navigating Latest Regs, Rulings and Guidance
Form 1120S Challenges for Enrolled Agents: Navigating Latest Regs, Rulings and Guidance Anticipating Issues With Computations, Dividends, Distributions, Fringe Benefits, Etc. THURSDAY, JUNE 27, 2013, 1:00-2:50
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 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 951A: GILTI Rules for Individual and Non C Corporation CFC Shareholders Treatment of CFC income, Reporting Requirements, Planning
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 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 informationSingle Sales Apportionment:
Presenting a live 110 minute teleconference with interactive Q&A Single Sales Apportionment: Crafting a Multi State Strategy Meeting Tax Compliance and Planning Demands Amid Significant Changes in Sales
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 informationBroker Dealer Auditing: Mastering New SEC and PCAOB Rules and Standards
Broker Dealer Auditing: Mastering New SEC and PCAOB Rules and Standards Complying With Changed Regulatory Framework for Conducting Audits and Attesting to Internal Controls WEDNESDAY, JANUARY 7, 2015,
More informationSALT Alert! : Significant Corporation Business Tax Changes Enacted in New Jersey
SALT Alert! 2018-11: Significant Corporation Business Tax Changes Enacted in New Jersey On July 1, 2018, New Jersey Governor Phil Murphy signed and conditionally vetoed a number of bills that implement
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 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 informationStructuring Waterfall Provisions in LLC and Partnership Agreements Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences
Presenting a 90-minute encore presentation featuring live Q&A Structuring Waterfall Provisions in LLC and Partnership Agreements Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences
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 informationNOL Treatment on Federal Corporate and Individual Tax Returns: Challenges for Preparers
NOL Treatment on Federal Corporate and Individual Tax Returns: Challenges for Preparers Navigating Computation, Sect. 382 Limitation, Carryback/Carryforward and Other Rules FRIDAY, NOVEMBER 16, 1:00-2:50
More informationForm 1120S Challenges for Tax Preparers
Form 1120S Challenges for Tax Preparers Navigating Computations-to-Adjustments Accounts and Determining Treatment of Dividends, Distributions and Fringe Benefits WEDNESDAY, DECEMBER 10, 2014, 1:00-2:50
More informationFiling Final Income Tax Return for Deceased Person: Mastering Allocations, Understanding IRD and More
Filing Final Income Tax Return for Deceased Person: Mastering Allocations, Understanding IRD and More FOR LIVE PROGRAM ONLY TUESDAY, SEPTEMBER 18, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationStructuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences
Presenting a live 110-minute webinar with interactive Q&A Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences THURSDAY,
More informationTransfer Pricing Implications for State & Local Tax
Transfer Pricing Implications for State & Local Tax G I A N LU CA P I T ET T I K P M G K E I T H R O B I NSON, P H D P WC I N S T I T U T E F O R P R O F E S S I O N A L S I N TA X AT I O N 2 0 1 6 I N
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 Allocation in Pass-Through Entities
Presenting a live 110-minute teleconference with interactive Q&A Tax Allocation in Pass-Through Entities Minimizing Tax Impact Through Strategic Allocation of Income, Gains, Losses and Liabilities THURSDAY,
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 informationWhirlwind Review of New State Tax Laws
Todd Lard, Partner Sutherland Asbill & Brennan LLP Carley Roberts, Partner Sutherland Asbill & Brennan LLP FTA Annual Conference June 10, 2014 Whirlwind Review of New State Tax Laws Agenda Factor Weighting
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 information