Successful Approaches Since the Fall
of Intangible Holding Companies
***States Continue to Eliminate Intangible
Asset and Royalty Deductions***
CD of Teleconference with Q&A
Conducted on Wednesday, August 6, 2008
Now available on CD
Sponsored by State Income Tax Monitor,
Tax Incentives Alert and Sales & Use Tax Monitor
Tax Teleconference Advisory Board
Recent changes in the law make it difficult for companies to leverage tax benefits from intercompany business activities. Intangible holding companies and passive investment companies are rare, and many states now declare income tax nexus on leasing intangible assets such as trademarks.
However, tax-saving opportunities have not completely vanished. Strategic corporate tax pros can scrutinize the nature of payments between related entities, how they conduct procurement and how they sell intangible assets to identify a different approach to trim tax exposure.
Staying abreast of evolving opportunities such as a successor to IHC and PIC structures is imperative for tax professionals and counsel to take advantage of their substantial savings potential.
Listen as our panel of veteran tax advisors points you toward tax planning strategies and practices that could be worth considering.
The panel included:
John Gilbert, Partner, State and Local Tax Practice Group, Pricewaterhouse Coopers, Boston. He specializes in income and sales taxation and has 28 years of experience with state tax. Previously in his career, he worked for the former Coopers & Lybrand and as Chief of Litigation for the Massachusetts Revenue Department.
Thomas Steele, Partner, Morrison & Foerster, San Francisco. He focuses on State and Local Tax matters and on defending technology and telecom companies' tax strategies in litigation. He has been a firm partner since 1982 and chairs the firm's West Coast State and Local Tax Practice Group.
Pilar Sansone, Associate, 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.
Peter Stathopoulos, Managing Director, State and Local Tax Group, Bennett Thrasher, Atlanta. He previously was a state tax partner for the McGuire Woods law firm, led the SALT Practice for Morris Manning & Martin, and was a principal consultant in the SALT Practice of PricewaterhouseCoopers.
The panel gives you the background and insights you need to start pursuing alternative approaches in these and other key areas:
- Evaluating whether your company has a good case to challenge a state's addback.
- Studying potential tax savings from reorganizing your corporate group along functional lines.
- Gaining a better understanding of the pros and cons of tax strategies involving intangible assets and procurement entities.
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.
CONTINUING LEGAL EDUCATION
CLE credit is available for an additional $65 each for attorneys seeking CLE credits for NY or CT.
Other states may grant CLE credits for listening to this CD - check with your state about applying for self-study credit on CD-listening.