of Intangible Holding Companies
CD of a Teleconference with Q&A
State legislatures and courts have forced the once-lucrative intangible holding company (IHC) and passive investment company (PIC) tax strategies out of existence. Many states now will declare income tax nexus on companies leasing intangible assets like trademarks from related entities.
However, new possibilities arose in the wake of those outlawed tax-planning strategies. For example, corporate parents might consider charging related entities service fees rather than royalties, creating embedded royalty companies, or selling intangible assets under Sect. 197.
Staying abreast of the new opportunities being crafted to replace IHCs and PICs is imperative for tax professionals and counsel in order to take advantage of their substantial savings potential.
Listen as our panel of veteran tax advisors updates you on evolving tax planning strategies and practices you can use now.
Our panel includes:
John Gilbert, Partner, State and Local Tax Group, PricewaterhouseCoopers, Boston.
Thomas Steele, Partner, Morrison & Foerster, San Francisco. As part of the firm's State and Local Tax Group, he focuses on defending technology and telecom companies' tax strategies in litigation. He chairs the firm's West Coast State and Local Tax Practice Group.
Kenneth Zemsky, Partner, Ernst & Young, New York. He specializes on state taxation and is a frequent lecturer and author on state tax matters. He has represented clients before New York state and city tax tribunals.
Pilar Sansone, Morrison & Foerster, San Francisco. She is attached to the firm's State and Local Tax Group, focusing on state and local tax controversies throughout the U.S.
The panel provides insights and guidance on:
- Performing a detailed review of your company's structure of legal entities.
- Implementing improvements in your tax department's modeling, making sure it's sufficiently dynamic across time and jurisdiction.
- Evaluating new technology products that can bolster your modeling capabilities.
- Understanding specific tax planning strategies now being employed by other corporations
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TELECONFERENCE CD
Purchase a CD-ROM of the full conference proceedings, including Q&A and PDF files of all handouts (available 10 days after the program).
- Regular Price - $247 (plus $9.45 S&H)
- With Teleconference Registration – an additional $75 (plus $9.45 S&H)
Self-study CPE is not offered on CD purchases.