New Federal Reportable Transaction Regulations

The IRS’ oversight of aggressive federal corporate income tax positions just keeps getting tougher. In-house corporate tax professionals and tax counsel need to know about the latest proposal for their company’ sake.

Regulations the IRS proposed in early November would create an entirely new category of tax-saving transactions that would require corporate taxpayers to report “transactions of interest” – those with the potential to get on the government’s bad side.

Clearly, the IRS wants to study evolving, aggressive tax strategies. However, exactly what a “transaction of interest” means is difficult to pin down: Being “substantially similar” to an already listed or reportable transaction leaves much to be interpreted.

Does the government have in mind a tax strategy that your company is already using? If so, what are the implications for your company?

Join us as our panel of savvy tax advisors such as Ellis Reemer of DLA Piper explains the IRS’ proposed new reportable transaction regulations. You’ll leave the teleconference well-briefed on the meaningful provisions of the regulations, and more importantly better-positioned to analyze the possible impact on your company.

• Julian Kim, partner, Latham & Watkins, Washington, specializes in complex federal and state tax controversies involving corporations. As a former acting deputy tax legislative counsel with the Treasury Department, he helped develop the government’s legislative and regulatory response to tax shelters.

• Ellis Reemer, Partner, DLA Piper, New York, represents clients in complex federal, state and local tax controversies and litigation. He is a former IRS senior trial attorney and has represented numerous corporate clients before the IRS regarding tax shelter disputes.

• Anita Soucy is an attorney-advisor in the Treasury Department’s office of tax policy, where she has principal responsibility for legislative matters in tax administration and procedure, including the proposed tax shelter regulations. Previously in her career, Anita was an attorney with Latham & Watkins in Washington, concentrating on tax controversy and litigation. She serves as an adjunct law professor at Georgetown University and is an active member of the ABA’s taxation section.

Among the key topics they’ll focus on are:

• What types of tax positions does the IRS really have in mind when it says “transactions of interest”.
• How to evaluate whether your company should report its current tax strategies.
• What is the IRS likely to do with the new intelligence it gathers.
• Whether your company might have to report “transactions of interest” from prior-year returns.
• Other relevant changes in the proposed regulations, including new returns and reports required from outside tax advisors and disclosure of patented tax strategies.

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TELECONFERENCE CD