Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
|
|
- Stanley Fox
- 5 years ago
- Views:
Transcription
1 Presenting a live 90-minute webinar with interactive Q&A Qualified Opportunity Zones and Tax Credits: New IRS Guidance, Capital Gain Deferral Mechanisms Under Section 1400Z IRC 45D(e) Requirements, Step-Up in Basis, Appreciation Exclusion, Tax Planning Strategies for Investors and More WEDNESDAY, JANUARY 23, pm Eastern 12pm Central 11am Mountain 10am Pacific Today s faculty features: Alan M. Blecher, JD, Principal, Marks Paneth, New York Elizabeth C. Crouse, Partner, K&L Gates, Seattle Michael I. Sanders, Partner, Blank Rome, Washington, D.C. The audio portion of the conference may be accessed via the telephone or by using your computer's speakers. Please refer to the instructions ed to registrants for additional information. If you have any questions, please contact Customer Service at ext. 1. NOTE: If you are seeking CPE credit, you must listen via your computer phone listening is no longer permitted.
2 Tips for Optimal Quality FOR LIVE EVENT ONLY Sound Quality If you are 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, you may listen via the phone: dial and enter your PIN when prompted. Otherwise, please send us a chat or sound@straffordpub.com immediately so we can address the problem. If you dialed in and have any difficulties during the call, press *0 for assistance. NOTE: If you are seeking CPE credit, you must listen via your computer phone listening is no longer permitted. Viewing Quality To maximize your screen, press the F11 key on your keyboard. To exit full screen, press the F11 key again.
3 Continuing Education Credits FOR LIVE EVENT ONLY In order for us to process your continuing education credit, you must confirm your participation in this webinar by completing and submitting the Attendance Affirmation/Evaluation after the webinar. A link to the Attendance Affirmation/Evaluation will be in the thank you that you will receive immediately following the program. For CPE credits, attendees must participate until the end of the Q&A session and respond to five prompts during the program plus a single verification code. In addition, you must confirm your participation by completing and submitting an Attendance Affirmation/Evaluation after the webinar. For additional information about continuing education, call us at ext. 2.
4 Program Materials FOR LIVE EVENT ONLY If you have not printed the conference materials for this program, please complete the following steps: Click on the ^ symbol next to Conference Materials in the middle of the lefthand column on your screen. Click on the tab labeled Handouts that appears, and there you will see a PDF of the slides for today's program. Double click on the PDF and a separate page will open. Print the slides by clicking on the printer icon.
5 Qualified Opportunity Zones and Tax Credits Presented by: Michael I. Sanders January 23, :00 2:30 PM ET Strafford Publications 2018 BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
6 INTRODUCTION INTRODUCTION Steven Mnuchin, Treasury Secretary, announced that the OZF legislation will prompt $100 billion in private investment in low income communities to reinvigorate dozens of cities, 8700 designated zones, covering 12 percent of the United States, and 35 million people BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
7 EXAMPLE: Angel investor sells high tech securities generating $10 million in capital gains Tax Act allows individuals and corporate investors to defer capital gains on the sale of stock business assets or other property (wherever located) by investing in a qualified opportunity zone (which must invest at least 90 percent of its assets, directly or indirectly in businesses located in designated opportunity zones (i.e., low income communities). The proceeds must be invested within 180 days beginning from the initial sale or exchange in the amount equal to the gain to be deferred. Moreover, there is partial forgiveness of the deferred capital gain if held for 5 or 7 years until 2026; and furthermore, any future gain on the investment in an opportunity fund may be excluded if the investment is held for 10 years BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
8 The deferred portion of the gain is taxable when the investment in the opportunity fund is sold or, if later, on December 31, 2026 unless the date is subsequently extended by Congress. So if the opportunity fund investment is held for 10 years, the tax basis of the new investment is deemed to be its fair market value on sale. In effect, further appreciation on the investment, but not the deferred gain, is eliminated permanently. It is important to note that the original property sold need not be located in or connected in any way with a qualified census tract BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
9 October, 2018, the Treasury Department issued additional guidance for the Opportunity Zone (OZ) incentive program. Specifically the Treasury Department issued a set of proposed regulations and a revenue ruling, both of which can be relied on by taxpayers. In addition to the proposed regulations and the revenue ruling, the Treasury Department also provided a draft Form 8996, the self-certification form for Qualified Opportunity Funds (QOFs), and corresponding instructions for the form BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
10 Although the additional guidance answers many questions that investors and practitioners have about the OZ incentive program, there are still a number of unanswered questions (some of which the Treasury Department is soliciting additional comments on), which we expect will be addressed in additional tranches of guidance issued from the Treasury Department BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
11 The OZF alternative is a remarkable opportunity for high net worth individuals to defer gain (such as $10 million in the example above) and subsequently exclude further gain based upon the appreciation of their investment in an opportunity zone. Moreover, and most important, it allows and incentivizes investments in qualified census tracts. Another benefit, increased value for real estate located in an Ozone; sales activities have picked up in OZs (See WSJ). Advice: Don t wait on sidelines. But many unanswered questions still remain: BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
12 ADDITIONAL QUESTIONS (SUBJECT TO ISSUANCE OF IRS GUIDELINES) What types of gains are eligible for reinvestment in a QOF? If I invest non-gain capital in a QOF, am I eligible for the ten-year exclusion benefit? Who is the taxpayer eligible for gain deferral? In a partnership context, do the proposed regulations allow flexibility as to the election to exclude gain for the partners? Does a taxpayer have to invest in a QOF by the end of 2019 in order to qualify for the full 15% basis increase? If I hold my QOF interest for ten years, at which point the QOF sells its assets and redeems my investment, is my allocable share of the gain with respect to such sales subject to tax? Or, do I actually have to sell my interest in the QOF in order to receive the ten-year exclusion benefit? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
13 Is there a grace period for a QOF to invest cash from an investor? Does residential rental property qualify as a qualified opportunity zone business? Is there an objective standard for active conduct of a trade or business? What constitutes a substantial portion of the intangible property used in the active conduct of a trade or business in the qualified opportunity zone? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
14 How is leased property of a QOZB or QOZBP to be treated? What constitutes a reasonable period for a QOF to reinvest proceeds from the sale of qualifying assets? Can property be aggregated at the QOZB level for purposes of determining whether the QOZB satisfies the substantial improvement test? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
15
16 Opportunity Zones: The Guidance (So Far) Elizabeth Crouse, K&L Gates LLP Copyright 2018 by K&L Gates LLP. All rights reserved.
17 The Guidance Notice : Designations REG : First round of Proposed Regulations Revenue Ruling : Land; substantial improvement Draft Form 8996: QOF election, annual filing December 2018 Executive Order: Order to agencies to facilitate klgates.com 17
18 Topics addressed to date How to become a QOF How to invest in a QOF How a QOF must invest its capital How to dispose of OZ investments The difference between original use and substantial improvement of QOZB property klgates.com 18
19 How to become a QOF Partnership or corporation Organized in the 50 states or DC Organized in possession if investment in possession Election before funding klgates.com 19
20 How to become a QOF klgates.com 20
21 How to invest in a QOF Recognize capital gain and invest it in equity issued by an entity that has already elected to be a QOF. How much gain? Whose gain? An eligible taxpayer is a person that may recognize gains for purposes of Federal income tax accounting. an eligible taxpayer may elect to defer recognition of some or all of its eligible gain Allocations of capital gain from partnership, RIC, REIT klgates.com 21
22 How to invest in a QOF How must the gain be generated? Rollovers When must investment be made? klgates.com 22
23 How to invest in a QOF What does taxpayer get in exchange? Basis Deferred gain portion Additional investment QOF s leverage? Preservation of tax attributes on deferred gain Gain deferral: earlier of sale or 12/31/2026 Deferred gain reduction: 5 or 7 year holds Gain elimination on QOF investment: 10 year hold klgates.com 23
24 How a QOF must invest its capital Substantially all 90% invested in QOZ property QOZB property QOZB equity Partnership or corporation Organized in the 50 states + DC Organized in a possession if investment in possession 70%+ of QOZB property must be qualified Newly issued equity Tax consequences of QOF s disposition of assets? klgates.com 24
25 How a QOF must invest its capital Compliance QOF measurements QOZB measurements Working capital safe harbors 1397C(b) requirements: active trade or business klgates.com 25
26 How to dispose of OZ investments Partial disposition Allocation methods: FIFO or pro rata 100% disposition Rollovers 10 year holding period to eliminate gain Election through 12/31/2047 Mixed investments require tracking klgates.com 26
27 Impact on structuring Opportunities vary by industry Technical impediments Everyone Basis limitations What is QOF/QOZB s basis in its assets? What is an active trade or business? Natural persons: at-risk, PAL Practical impediments Location, location, location Fund management klgates.com 27
28 Structuring opportunities QOF+, QOF++ models Nonrecourse leverage Split the baby Renewables models Creative management solutions klgates.com 28
29
30 Section 1400Z-2 Opportunity Zones Selected Tax Accounting Issues January 23, 2019 Al Blecher, JD MARKS PANETH 30
31 Selected Tax Accounting Issues Many of the tax accounting issues in the QOF arena arise due to the uncertain intersection of new Section 1400Z-2 with the long established partnership tax accounting rules The guidance regarding basis adjustments to QOF partnership interests is limited and does not always dovetail neatly with the partnership tax rules Under the general partnership tax accounting rules, a partner s basis in its partnership interest is equal to the partner s initial capital contribution to the partnership, and is subsequently increased by its distributive share of the partnership s income and decreased (but not below zero) by distributions by the partnership to the partner and the partner s distributive share of the losses of the partnership Section 752 provides that if the partnership incurs debt, the partner s share of the debt allocated to it under the special rules pertaining to such allocations is deemed to be a contribution by the partner to the partnership; a decrease in the amount of debt allocated to the partner is deemed to be a distribution by the partnership to the partner 31 MARKS PANETH MARKS PANETH 31
32 Tax Accounting (continued) However, the QOF rules state that except as otherwise provided therein, the taxpayer s basis in its eligible-gain investment shall be zero The statutory otherwise provided exceptions to the zero basis rule are that basis is increased by 5-year, 7-year, December 31, 2026 and 10-year sale adjustments but other basis adjustments otherwise available appear to be excluded The proposed regulations provide that the Section 752 partnership basis increase is not a partner contribution of money that is subject to the mixed investment bifurcation rules for non-gain QOF investments The proposed regulations suggest that the Section 752(a) tax basis increase is allowed for other tax purposes, which may permit a QOF to allocate tax losses to the QOF investors to the extent of said debt 32 MARKS PANETH MARKS PANETH 32
33 Tax Accounting (continued) Under general partnership tax accounting rules, when a partner s basis is increased due to the allocation of partnership debt, and this leveraged basis is used to support the deduction of partnership losses, such cumulative leveraged losses are recaptured into income via the inclusion of the liabilities in the amount realized upon the disposition of the partnership interest Selected Tax Accounting Issues: Does the special rule regarding the exclusion of gain for QOF interests held for at least 10 years exclude not only the gain on the QOF partner s eligible gain interest appreciation but also eliminate the recapture of cumulative leveraged losses? Does the initial zero basis rule also require a zero basis in the eligible-gain QOF investment when the QOF partnership later has undistributed taxable income or incurs debt? Does the initial zero basis rule mean that the QOF takes a zero basis in the assets that the QOF holds? 33 MARKS PANETH MARKS PANETH 33
34 Tax Accounting (continued) How does the single basis rule of Rev. Rul ( a partner has a single basis in a partnership interest ) apply in the context of a mixed-fund investment in a QOF? Can an eligible-gain investor in a QOF partnership be allocated losses if it has no noneligible gain interest and no Section 752-derived debt basis? If a partner purchases an interest in a partnership that has previously made a QOF investment, can the new partner reduce its share of the partnership s gain recognized in 2026 via a Section 743(b) step up? Comparing the tax treatment of a QOF s disposition of a QOZBP vs the sale of an eligible-gain QOF partnership interest, in light of the apparent purpose of the QOZ provisions 34 MARKS PANETH
35 If a sponsor invests gain dollars in a QOF for a 1% interest and has a carried interest in the QOF such that their 1% interest flips to 20% upon a capital event, is the carried interest eligible for forgiveness assuming a 10-year hold? If a QOF or a QOZB partnership were to refinance its property upon stabilization and make a debt financed distribution to a QOF partner that reduces their investment, does the distribution trigger an end to the deferral period? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
36 With regard to the nonqualified financial property safe harbor, that is, the 31-month working capital rule, how is the taxpayer to designate property? What happens if a taxpayer plans to purchase properties A and B, and instead, purchases property B and C for a similar amount? Is this substantially consistent? Since the new entity doesn t have to be a QOZB at the time the QOF invests and only has to be a QOZB for substantially all of the QOF s holding period, does this imply that a new business has time to become a QOZB? (Treasury should provide a grace period of perhaps 2 years time in order to meet the QOZB test.) BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
37 With regard to the use of intangible property, the requirement with respect to any taxable year is that a substantial portion of the intangible property of a QOZB is used in the active conduct of a trade or business in the qualified opportunity zone. In this context what does substantial mean? A secondary issue concerns whether the intangible property needs to be located in a qualified opportunity zone, i.e., the situs BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
38 Is it better to invest in OZBP directly or Indirectly? I own property located in a QOZ that I purchased in 2017 is there a way to have the property transferred to the QOF that I am sponsoring? If my QOF acquires 10 acres of vacant land and intends to substantially improve it with a single high-rise multifamily tower, will all of the land be deemed substantially improved (assuming the basis addition requirements of the substantial improvement test are otherwise satisfied)? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
39 If my QOF intends to satisfy the substantial improvement test with respect to property it acquires, does the project need to be placed into service within 30 months after acquisition? I really do not like limited partnerships can I form my QOF as a limited liability company? Is it better to be a corporation or a partnership QOF? I understand that the first measuring date for the 90% asset test is on the last day of the first six-month period of the taxable year of my QOF but what if my QOF is formed after July 1 such that the first sixmonth period after formation straddles into the following taxable year? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
40 I understand that cash is considered a bad asset for purposes of the 90% asset test how long do I have to deploy cash contributed to my QOF into good assets? If I have a single sale that produces $10m of gain, can I diversify my reinvestment by investing $1m into ten different QOFs, or am I only limited in making the deferral election with respect to one QOF? If I intend to qualify my investment vehicle as a QOF but later determine it is not possible to satisfy the 90% asset test, can I simply withdraw my QOF certification in order to avoid the imposition of monthly penalties? If a QOF investor dies before the end of the deferral period, is the deferred gain exempt from tax? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
41 If I fail to reinvest gain into a QOF within 180 days of the date of the transaction that produced such gain, is there any relief? I understand a taxpayer has zero basis in their deferred gain invested in a QOF. Does this mean that a Fund or QOZB also have zero basis in the portion of assets sourced with this investment and therefore no depreciation benefits? BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
42 PAIRING OPPORTUNITY ZONE INCENTIVES WITH NMTCS PAIRING OPPORTUNITY ZONE INCENTIVES WITH NMTCS Build on the initial deferral technique by investing in OZF. Through the NMTC structure, the investor can take advantage of the leveraging structure and generate tax credits over a 7 year period. So not only can the capital gains be deferred for a 9 year period, including an increase in basis with partial forgiveness after 5 and 7 year holding period, but the taxpayer can receive incremental benefit through the tax credit regime. Investor likely to be C Corporation in view of the AMT, which was retained as to individuals BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
43 Sufficient basis needed to absorb the required NMTC basis adjustment. Accordingly OZ deferral election will be limited to the QEI less the sub CDE fees and the NMTCs that are generated. It is important to note that QALICB must also be a qualified opportunity zone business (which should be relatively easy to accomplish in view of the similarities of the programs) BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
44 Sub CDEs will need to obtain the status of a QOF, however, may now self-certify. The QLICIs need to be an equity investment under the OZ rules; as a result, the investors may not be able to rely on the reasonable expectation safe harbor test (affects issuance of tax opinions). Existing CDEs may need to get approval from CDFI Fund if the making equity QLICIs is not consistent with their approved business strategy BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
45 USE BY TAX EXEMPT ORGANIZATIONS: WIN-WIN USE BY TAX EXEMPT ORGANIZATIONS: WIN-WIN Opportunity Funds may be purchased and sold similar to mutual funds. A fund could invest in all aspects of mixed use development in designated qualified census tracts beneficial to low income exempt organizations. It incentivizes urban renewal as well as rural development, allowing developers to create and expand communities with new multi-family housing and retail venues. It may also attract angel investors and incubators, along with venture capitalists thereby attracting companies to locate in opportunity zones, where after a 10 year hold, a liquidation may generate millions of dollars in capital gains with permanently exclusion from taxation BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
46 There are many reasons why a nonprofit should form joint ventures or a for-profit subsidiary to directly partner with the OZF, to operate in the designated low income high unemployment zones, consistent with its exempt function. Because the law favors new businesses, new construction, start-ups and incubators may be motivated by the incentives. Thus, an opportunity fund could operate or fund a new technology or healthcare business in the zone. A successful tech start-up could experience significant growth over a decade, allowing the investor a large permanent exclusion from taxation. Community healthcare and food deserts are also sorely needed in many lowincome communities, and walk-in clinics and urgent care facilities, already growing in popularity, may also be attractive projects for opportunity funds BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
47 PRELIMINARY STEPS IN FORMATION OF OPPORTUNITY FUND PRELIMINARY STEPS IN FORMATION OF OPPORTUNITY FUND 1. Formation of Opportunity Zone Fund (OZF) as a corporation or a partnership for purposes of investing in Qualified Opportunity Zone Property ( QOZF ): use of an LP/Query: will an LLC qualify as a OZF? 2. General Partner of the LP: formation of the limited liability company; operations of OZF. 3. Management Company: formation of the limited liability company that will act as a management company; fee structure Terms of the Investment Management Agreement. Confirmation of designation as QCT by Governors, approved by Treasury BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
48 6. Self-certification of OZF based upon IRS Frequently Asked Questions. To self-certify, a taxpayer merely completes a form (to be released in summer of 2018), which is attached to taxpayer s federal income tax return. 7. Preparation of OZF Business Plan (reviewed by counsel), including land and building acquisition, timing. 8. Draft of private placement memorandum. 9. Draft of the Subscription Agreement. 10. Review of exemptions under the Securities Act, state blue sky laws, and the Investment Advisers Act BLANK ROME LLP. ALL RIGHTS RESERVED. PLEASE CONTACT BLANK ROME FOR PERMISSION TO REUSE.
Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Qualified Opportunity Zones and Tax Credits: Capital Gain Deferral Mechanisms Under New Section 1400Z IRC 45D(e) Requirements, Step-Up in Basis,
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features: James O. Lang, Shareholder, Greenberg Traurig, Tampa, Fla.
Presenting a live 90-minute webinar with interactive Q&A Leveraging New Markets Tax Credits to Finance Community Development: Latest Regs, Guidance and Legal Developments Twinning With Historic Tax Credits,
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 informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Qualified Opportunity Zones: New Tax Incentives for Commercial Real Estate and Other Investments Deferred Capital Gains and Tax Abatement Under
More informationScott J. Bakal, Partner, Neal Gerber & Eisenberg, Chicago Robert C. Stevenson, Attorney, Skadden Arps Slate Meagher & Flom, Washington, D.C.
Presenting a live 90-minute webinar with interactive Q&A : Tax Basis Step-Up Through Deemed Asset Sale Treatment Structuring Qualifying Stock Dispositions for Partnership and Private Equity Acquirers WEDNESDAY,
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Brian E. Hammell, Esq., Sullivan & Worcester, Boston
Presenting a live 90-minute webinar with interactive Q&A Buy-Sell Agreements for Corporations and LLCs: Drafting Stock Redemption, Cross-Purchase and Mixed Agreements Navigating Complex Corporate, Tax,
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 informationCreatively Completing The Capital Stack: Real Estate GP Private Equity Funds
Presenting a live 90-minute webinar with interactive Q&A Creatively Completing The Capital Stack: Real Estate GP Private Equity Funds Structuring Key Deal Terms Regarding Distribution, Sharing of Promote
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 Equity Joint Ventures: Structuring Capital Contribution, Waterfall and Other Payment Provisions Promoted Interest, Carried Interest, Cash Flow Splits
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 informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Grantor Trusts After Divorce: Tax Reform, Fiduciary Challenges, and Minimizing Tax for Trust Transfers to Former Spouse Gift Tax Exemption on Divorce
More informationAsset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting and Structuring Techniques for Tax Counsel
Presenting a live 90-minute webinar with interactive Q&A Asset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting and Structuring Techniques for Tax Counsel TUESDAY, AUGUST 2, 2016 1pm Eastern
More informationQDRO Drafting Boot Camp: Preparing QDROs for 401(k)s and Similar Defined Contribution Plans
Presenting a live 90-minute webinar with interactive Q&A QDRO Drafting Boot Camp: Preparing QDROs for 401(k)s and Similar Defined Contribution Plans Strategies for Family Law Practitioners to Help Ensure
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 NING and DING Trusts in Estate Planning: Designing ING Trusts to Avoid State Income Tax and Protect Assets Effective Drafting of Incomplete Gift
More informationCommercial Lease Negotiations: Property and Liability Insurance, Proof of Coverage, AI and Loss Payee Issues
Presenting a live 90-minute webinar with interactive Q&A Commercial Lease Negotiations: Property and Liability Insurance, Proof of Coverage, AI and Loss Payee Issues Structuring Lease Provisions to Require
More informationEstate Planning and Tax Reform: Wealth Transfer Structures Under the New Tax Law
Presenting a live 90-minute webinar with interactive Q&A Estate Planning and Tax Reform: Wealth Transfer Structures Under the New Tax Law WEDNESDAY, FEBRUARY 7, 2018 1pm Eastern 12pm Central 11am Mountain
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 informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Choice of Entity Under the New Tax Law: Avoiding Tax Pitfalls in Operations, Ownership Changes, Exit Strategies Capital vs. Profits Interest, Allowable
More informationTax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations, Distributions, and More
Presenting a live 90-minute webinar with interactive Q&A Tax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations, Distributions, and More Structuring Provisions to Achieve
More informationPrivate Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors
Presenting a live 90-minute Encore Presentation of the Webinar with Live, Interactive Q&A Private Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Elizabeth A. Gartland, Esq., Fenwick & West, San Francisco
Presenting a live 90-minute webinar with interactive Q&A Structuring Management Carve-Out Plans for Privately Held Corporations: Mechanics, Tax Obstacles and Optimization Guidance for Employee Benefits
More informationCompletion Guaranties in Construction Lending: Key Provisions for Lenders and Guarantors
Presenting a live 90-minute webinar with interactive Q&A Completion Guaranties in Construction Lending: Key Provisions for Lenders and Guarantors TUESDAY, MARCH 6, 2018 1pm Eastern 12pm Central 11am Mountain
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 informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Dean C. Berry, Partner, Cadwalader Wickersham & Taft, New York
Presenting a live 90-minute webinar with interactive Q&A Estate Planning Involving Resident and Non-Resident Aliens Navigating Estate, Gift and GST Tax Rules; Leveraging Estate and Lifetime Gifting Opportunities
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 Tax Reform: Impact on REITs, Real Estate Businesses and Investors Pass-Through Business and Interest Deductions, Cost Recovery, Carried Interest,
More informationIRS Publishes Opportunity Zone Proposed Regulations: The First Important Step in the Structuring of OZ Funds
Qualified Opportunity Zone Funds OCTOBER 2018 NO. 2 IRS Publishes Opportunity Zone Proposed Regulations: The First Important Step in the Structuring of OZ Funds As part of the Tax Cuts and Jobs Act (the
More informationUsing Partnership Flips to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating IRS Safe Harbors
Presenting a live 90-minute webinar with interactive Q&A Using Partnership Flips to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating IRS Safe Harbors THURSDAY, JULY 26, 2018 1pm Eastern
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 Structuring and Operating Family Limited Partnerships: Asset Protection and Income Tax Reduction Shifting Income Tax Burden to Lower-Taxed Family
More informationUniversal Health Services v. Escobar: Avoiding Implied Certification Liability Under FCA
Presenting a live 30-minute webinar with interactive Q&A Universal Health Services v. Escobar: Avoiding Implied Certification Liability Under FCA MONDAY, JULY 25, 2016 1pm Eastern 12pm Central 11am Mountain
More informationPrivate Equity Real Estate Fund Formation: Capital Raising, Regulatory Issues and Negotiating Trends
Presenting a live 90-minute webinar with interactive Q&A Private Equity Real Estate Fund Formation: Capital Raising, Regulatory Issues and Negotiating Trends Capital Contributions, Allocation of Profits/Losses,
More informationFinancing Multi-Family Housing: Structuring the Low Income House Tax Credit and Tax-Exempt Bonds Documenting Transactions for Investors and Developers
Presenting a live 90-minute webinar with interactive Q&A Financing Multi-Family Housing: Structuring the Low Income House Tax Credit and Tax-Exempt Bonds Documenting Transactions for Investors and Developers
More informationERISA Retirement Plan Investment Management Agreements: Guidance for Plan Sponsors to Minimize Risks
Presenting a live 90-minute webinar with interactive Q&A ERISA Retirement Plan Investment Management Agreements: Guidance for Plan Sponsors to Minimize Risks Selecting 3(38) Investment Managers, Negotiating
More informationUsing Inverted Leases to Finance Renewable Energy Projects
Presenting a live 90-minute webinar with interactive Q&A Using Inverted Leases to Finance Renewable Energy Projects Evaluating Tax Risks, Navigating Structural Variations, Leveraging Pass-Through Election
More informationUsing Partnership Flips to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating IRS Safe Harbors
Presenting a live 90-minute webinar with interactive Q&A Using Partnership Flips to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating IRS Safe Harbors THURSDAY, JANUARY 26, 2017 1pm Eastern
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 Transactional Risk Insurance in M&A: Reps and Warranties, Contingent Liability and More Leveraging Insurance to Allocate Risk and Protect Deal Value;
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 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 informationIRC Section 338(h)(10) Election
Presenting a live 110 minute teleconference with interactive Q&A IRC Section 338(h)(10) Election Strategies for Tax Counsel Leveraging the Election in Structuring Acquisitions, Dispositions and Asset and
More informationSurvivor Benefit Plans and Military Divorce: Defending Against or Claiming Former-Spouse SBP Coverage
Presenting a live 90-minute webinar with interactive Q&A Survivor Benefit Plans and Military Divorce: Defending Against or Claiming Former-Spouse SBP Coverage WEDNESDAY, JUNE 28, 2017 1pm Eastern 12pm
More informationDistressed Loan Workouts: How Equity Cure Rights Work, Negotiating Loan Restructuring and Forbearance Agreements
Presenting a live 90-minute webinar with interactive Q&A Distressed Loan Workouts: How Equity Cure Rights Work, Negotiating Loan Restructuring and Forbearance Agreements Curing and Addressing Financial
More informationClearing Title for Defects Due to Mortgage-Related Issues, Legal Description Errors, and Foreclosure
Presenting a live 90-minute webinar with interactive Q&A Clearing Title for Defects Due to Mortgage-Related Issues, Legal Description Errors, and Foreclosure Identifying and Resolving Common Title Defects
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 Private Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors Distributions, Clawbacks
More informationERISA Compliance and Monitoring 401(k) Investments: Safe Harbor Rules and Appointing Advisers
Presenting a live 90-minute webinar with interactive Q&A ERISA Compliance and Monitoring 401(k) Investments: Safe Harbor Rules and Appointing Advisers TUESDAY, APRIL 3, 2018 1pm Eastern 12pm Central 11am
More informationERISA Pre-Approved and Customized Benefit Plans: Overhauled IRS Procedures and Determination Letter Process
Presenting a live 90-minute webinar with interactive Q&A ERISA Pre-Approved and Customized Benefit Plans: Overhauled IRS Procedures and Determination Letter Process TUESDAY, NOVEMBER 14, 2017 1pm Eastern
More information401(k) Plan Nondiscrimination Testing: Guidance for Employee Benefits Counsel
Presenting a live 90-minute webinar with interactive Q&A 401(k) Plan Nondiscrimination Testing: Guidance for Employee Benefits Counsel Meeting IRS Requirements, Avoiding Corrective Distributions, Evaluating
More informationSpringing the Delaware Tax Trap: Drafting Limited Powers of Appointment to Increase Asset Income Tax Basis
Presenting a live 90-minute webinar with interactive Q&A Springing the Delaware Tax Trap: Drafting Limited Powers of Appointment to Increase Asset Income Tax Basis TUESDAY, JUNE 28, 2016 1pm Eastern 12pm
More informationUCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests
Presenting a live 90-minute webinar with interactive Q&A UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests Navigating Statutory, Contractual and Other Exclusions to All
More informationEstate Planning With Grantor Trusts: Leveraging GRATs and IDGTs to Minimize Taxes, Preserve and Transfer Assets
Presenting a live 90-minute webinar with interactive Q&A Estate Planning With Grantor Trusts: Leveraging GRATs and IDGTs to Minimize Taxes, Preserve and Transfer Assets THURSDAY, OCTOBER 15, 2015 1pm Eastern
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 informationReporting Costs of Health Insurance on Employee W-2s: New Requirements
Presenting a live 110-minute teleconference with interactive Q&A Reporting Costs of Health Insurance on Employee W-2s: New Requirements Mastering the Procedures for Disclosing and Valuing Coverage Starting
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 informationReal Estate Transactions With REITs: Selling, Leasing or Lending to a REIT
Presenting a 90-Minute Encore Presentation of the Webinar with Live, Interactive Q&A Real Estate Transactions With REITs: Selling, Leasing or Lending to a REIT Navigating Unique Organizational, Operational
More informationMinority Investors in LLCs: Contractual Limitations, Waivers of Fiduciary Duties, Other Key Provisions
Presenting a live 90-minute webinar with interactive Q&A Minority Investors in LLCs: Contractual Limitations, Waivers of Fiduciary Duties, Other Key Provisions Protecting Minority Interests, Choice of
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 informationPresenting a live 110-minute teleconference with interactive Q&A. Today s faculty features:
Presenting a live 110-minute teleconference with interactive Q&A Taxation and Financial Reporting of Investments in Securities and Related Complex Transactions Tackling Financial Statement Challenges and
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 Keys To Equity Financing: The Compliance Requirements for Lenders and Borrowers Structuring Loans Secured by Stock, Hedge Fund Shares, 40 Act Companies
More informationUCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests
Presenting a live 90-minute webinar with interactive Q&A UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests Navigating Statutory, Contractual and Other Exclusions to All
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 D&O Indemnification Provisions in Governance Documents and Agreements Drafting Effective Indemnity and Advancement Agreements to Protect Directors
More informationU.S.-Israeli Estate Tax Planning for Dual Citizens
Presenting a 90-Minute Encore Presentation of the Webinar with Live, Interactive Q&A U.S.-Israeli Estate Tax Planning for Dual Citizens Reconciling U.S. and Israeli Law on Trust Taxation, Inheritance Laws,
More informationProperty Management and Leasing Agreements: Key Provisions for Multi-Family, Office, Retail and Industrial Properties
Presenting a live 90-minute webinar with interactive Q&A Property Management and Leasing Agreements: Key Provisions for Multi-Family, Office, Retail and Industrial Properties Navigating Fees and Expenses,
More informationForeign Investment in U.S. Real Estate: Impact of Tax Reform
Presenting a live 90-minute webinar with interactive Q&A Foreign Investment in U.S. Real Estate: Impact of Tax Reform Entity Selection, FIRPTA, Tax Concerns When Acquiring or Disposing of Ownership Interests
More informationInterest Rate Hedges in Real Estate Finance: Placing Swaps, Caps, and Collars on Floating Rate Loans
Presenting a live 90-minute webinar with interactive Q&A Interest Rate Hedges in Real Estate Finance: Placing Swaps, Caps, and Collars on Floating Rate Loans Understanding Pricing and Trade Confirmations,
More informationIC-DISC: Compliance Challenges in the Federal Tax Break for Exporters
Presenting a live 110-minute teleconference with interactive Q&A IC-DISC: Compliance Challenges in the Federal Tax Break for Exporters Leveraging Benefits Arising From the Dividend Tax Solution WEDNESDAY,
More informationInvestment Adviser Advertising Rule: New SEC Guidance and Best Practices for Compliance
Presenting a live 90-minute webinar with interactive Q&A Investment Adviser Advertising Rule: New SEC Guidance and Best Practices for Compliance TUESDAY, NOVEMBER 21, 2017 1pm Eastern 12pm Central 11am
More informationFraudulent Conveyance Exposure for Intercorporate Guaranties, Integrated Transactions and Designated-Use Loans
Presenting a live 90-minute webinar with interactive Q&A Fraudulent Conveyance Exposure for Intercorporate Guaranties, Integrated Transactions and Designated-Use Loans Navigating the Contours of Section
More informationStructuring Commercial Loan Documents to Protect Non-Affiliated Lenders
Presenting a live 90-minute webinar with interactive Q&A Structuring Commercial Loan Documents to Protect Non-Affiliated Lenders Negotiating and Drafting Provisions Involving Loan Buybacks, Additional
More informationPresenting a live 110-minute teleconference with interactive Q&A
Presenting a live 110-minute teleconference with interactive Q&A Valuation Challenges With $10 Million-and-Under Businesses Avoiding Mistakes With Built-In Gains and Taxes, Misuse of Market Data and Other
More informationERISA Considerations in Structuring Credit Facilities with Private Investment Funds
Presenting a live 90-minute webinar with interactive Q&A ERISA Considerations in Structuring Credit Facilities with Private Investment Funds WEDNESDAY, AUGUST 15, 2018 1pm Eastern 12pm Central 11am Mountain
More informationAllocating Operating Expenses in Commercial Real Estate Leases: Negotiating Strategies for Landlords and Tenants
Presenting a live 90-minute webinar with interactive Q&A Allocating Operating Expenses in Commercial Real Estate Leases: Negotiating Strategies for Landlords and Tenants Structuring Pass-Throughs, Exclusions,
More informationBest Efforts and Commercially Reasonable Efforts in M&A Agreements: Drafting and Interpretation Challenges
Presenting a live 90-minute webinar with interactive Q&A Best Efforts and Commercially Reasonable Efforts in M&A Agreements: Drafting and Interpretation Challenges Lessons From Case Law for Interpreting
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 informationProtecting Business Assets From Creditors in Litigation: Strategic Choice of Entities, Avoiding Fraudulent Transfers
Presenting a live 90-minute webinar with interactive Q&A Protecting Business Assets From Creditors in Litigation: Strategic Choice of Entities, Avoiding Fraudulent Transfers TUESDAY, JULY 21, 2015 1pm
More information30(b)(6) Depositions in Insurance Coverage and Bad Faith Litigation Preparing and Responding to Notices of Corporate Representative Depositions
Presenting a live 90-minute webinar with interactive Q&A 30(b)(6) Depositions in Insurance Coverage and Bad Faith Litigation Preparing and Responding to Notices of Corporate Representative Depositions
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 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 informationTax Challenges for NPO Counsel: Excess Benefit Transactions for Executive Comp and Other Financial Dealings
Presenting a live 110-minute teleconference with interactive Q&A Tax Challenges for NPO Counsel: Excess Benefit Transactions for Executive Comp and Other Financial Dealings Identifying Prohibited Transactions
More informationTax Treatment of Carried Interest: Planning Opportunities for Tax, Private Equity and Real Estate Professionals
Presenting a 90-minute encore presentation featuring live Q&A Tax Treatment of Carried Interest: Planning Opportunities for Tax, Private Equity and Real Estate Professionals IRC Section 1061, Capital Contributions,
More informationExercising Setoff and Recoupment Rights in Bankruptcy
Presenting a live 90-minute webinar with interactive Q&A Exercising Setoff and Recoupment Rights in Bankruptcy Mutuality of Obligation; Disputed Transactions; Relief From Automatic Stay TUESDAY, NOVEMBER
More informationStructuring Commercial Loan Term Sheets, Proposals and Commitment Letters: Key Terms for Lenders and Borrowers
Presenting a live 90-minute webinar with interactive Q&A Structuring Commercial Loan Term Sheets, Proposals and Commitment Letters: Key Terms for Lenders and Borrowers Avoiding Unintended Consequences
More informationAttendees seeking CPE credit must listen to the audio over the telephone.
Presenting a live 110 minute teleconference with interactive Q&A New 3.8% Net Investment Income Tax: Planning for Closely Held Companies Navigating New Medicare Tax, Self Employment l Tax, and Capital
More informationBank Affiliate Transactions Under Scrutiny Complying With Regulation W's Complex Restrictions on Business Dealings with Affiliate Institutions
Presenting a live 90-minute webinar with interactive Q&A Bank Affiliate Transactions Under Scrutiny Complying With Regulation W's Complex Restrictions on Business Dealings with Affiliate Institutions TUESDAY,
More informationInsurance Coverage for Statutory and Liquidated Damages and Attorney Fees: Policyholder and Insurer Perspectives
Presenting a live 90-minute webinar with interactive Q&A Insurance Coverage for Statutory and Liquidated Damages and Attorney Fees: Policyholder and Insurer Perspectives Advocating Coverage for Statutory
More informationTax Challenges With Private Equity Management Fee Waivers Given Newly Heightened IRS Scrutiny
Presenting a live 90-minute webinar with interactive Q&A Tax Challenges With Private Equity Management Fee Waivers Given Newly Heightened IRS Scrutiny Structuring Waiver Arrangements in Light of the Proposed
More informationNew Markets Tax Credits: Where Are We Now, Exiting or Restructuring Existing Deals, and Traps for the Unwary
Presenting a live 90-minute webinar with interactive Q&A New Markets Tax Credits: Where Are We Now, Exiting or Restructuring Existing Deals, and Traps for the Unwary Qualifying for Tax Credits and Meeting
More informationGrantor Retained Annuity Trusts in 2013: Tax-Efficient Estate Planning Techniques Leveraging GRATs to Preserve and Transfer Assets
Presenting a live 90-minute webinar with interactive Q&A Grantor Retained Annuity Trusts in 2013: Tax-Efficient Estate Planning Techniques Leveraging GRATs to Preserve and Transfer Assets WEDNESDAY, MARCH
More informationHigh Volatility Commercial Real Estate Loans: Guidance for Developers and Lenders on HVCRE Rules and Loan Covenants
Presenting a 90 minute encore presentation High Volatility Commercial Real Estate Loans: Guidance for Developers and Lenders on HVCRE Rules and Loan Covenants Navigating Borrower Contributed Capital Rules,
More informationStructuring Employee Severance Arrangements: Revisiting Code Section 409A and its Impact on Deferred Compensation
Presenting a live 90-minute webinar with interactive Q&A Structuring Employee Severance Arrangements: Revisiting Code Section 409A and its Impact on Deferred Compensation TUESDAY, JULY 26, 2016 1pm Eastern
More informationZombie Corporations and CERCLA Liability: Identifying, Reviving and Pursuing Zombie PRPs
Presenting a live 90-minute webinar with interactive Q&A Zombie Corporations and CERCLA Liability: Identifying, Reviving and Pursuing Zombie PRPs TUESDAY, APRIL 3, 2018 1pm Eastern 12pm Central 11am Mountain
More informationTrucking and Auto Injury Cases: Deposing Accident Reconstruction and Biomechanical Experts
Presenting a live 90-minute webinar with interactive Q&A Trucking and Auto Injury Cases: Deposing Accident Reconstruction and Biomechanical Experts WEDNESDAY, JULY 11, 2018 1pm Eastern 12pm Central 11am
More informationStructuring Preferred Equity Investments in Real Estate Ventures: Impact of True Equity vs. "Debt-Like" Equity
Presenting a live 90-minute webinar with interactive Q&A Structuring Preferred Equity Investments in Real Estate Ventures: Impact of True Equity vs. "Debt-Like" Equity Negotiating Deal Terms, Investor
More informationPartnership Exchanges: Structuring "Drop and Swap" and "Mixing Bowl" Transactions Minimizing the Risk of an Unfavorable Audit Outcome
Presenting a live 90-minute webinar with interactive Q&A Partnership Exchanges: Structuring "Drop and Swap" and "Mixing Bowl" Transactions Minimizing the Risk of an Unfavorable Audit Outcome WEDNESDAY,
More informationTax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations and Distributions, and More
Presenting a live 90-minute webinar with interactive Q&A Tax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations and Distributions, and More TUESDAY, APRIL 3, 2018 1pm
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Matthew B. Grunert, Partner, Andrews Kurth Kenyon, Houston
Presenting a live 90-minute webinar with interactive Q&A SEC s Pay Ratio Disclosure Rule for CEO and Median Employee Compensation Data Gathering, Calculation Methodologies, Preparing for Heightened Stakeholder
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 Drafting Standstills in Intercreditor Agreements: Balancing Rights and Remedies of Junior and Senior Lienholders Structuring Duration, Commencement,
More informationCorporate Governance of Subsidiaries: Board Roles and Responsibilities, Interplay With Parent Board, Liability Risks
Presenting a live 90-minute webinar with interactive Q&A Corporate Governance of Subsidiaries: Board Roles and Responsibilities, Interplay With Parent Board, Liability Risks THURSDAY, AUGUST 16, 2018 1pm
More informationUCC Article 9 Update: Searching and Filing Under New Amendments
Presenting a live 90-minute webinar with interactive Q&A UCC Article 9 Update: Searching and Filing Under New Amendments Lessons Learned Under the Recent Rules, Best Practices for Secured Lenders WEDNESDAY,
More information401(k) Plan Audit Preparation Strategies Navigating IRS and DOL Standards, Taking Corrective Actions and Minimizing Risks of Penalties
Presenting a live 110 minute teleconference with interactive Q&A 401(k) Plan Audit Preparation Strategies Navigating IRS and DOL Standards, Taking Corrective Actions and Minimizing Risks of Penalties WEDNESDAY,
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 informationDrafting Shareholder Agreements for Private Equity M&A Deals
Presenting a live 90-minute webinar with interactive Q&A Drafting Shareholder Agreements for Private Equity M&A Deals Structuring Provisions on Board Composition and Duties, Drag-Along, Tag-Along, Information
More informationImpact of Tax Reform on ABLE Accounts and Special Needs Trusts: Guidance for Elder Law Attorneys
Presenting a live 90-minute webinar with interactive Q&A Impact of Tax Reform on ABLE Accounts and Special Needs Trusts: Guidance for Elder Law Attorneys THURSDAY, SEPTEMBER 27, 2018 1pm Eastern 12pm Central
More information