Business Entity Conversions: Income Tax Consequences You May Not Anticipate
Understanding and Navigating Complex Federal Income Tax Implications
Recording of a 110-minute CPE webinar with Q&A
This teleconference will provide tax advisors and corporate tax specialists with an explanation of the steps that should be taken in analyzing federal tax implications in a conversion to a different business entity.
- Current trends in federal and state law and regs on converting legal entities
Process for converting entities
- C corporations
- General partnerships, LLPs and LLLPs
- S corporations
Tax implications to consider in restructuring entities
- Pitfalls contained in IRC §351 and IRC §357(c)
- Income tax nexus-triggering activities
- Effective tax rates calculation under FAS 109 and FIN 48
- Other issues
- Best practices for a coordinated approach to entity restructuring
The panel will explore these and other on-point topics:
- Structural changes: What is involved in converting an entity?
- Potential pitfalls in IRC §351 and IRC §357(c): How can a conversion be kept tax-free?
- FAS 109/FIN 48 disclosures: Is too much time being spent calculating effective tax rates because of outmoded entities?
- 83(b) elections: How do they affect the conversion?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Joseph K. Fletcher, III
Glaser Weil Fink Howard Avchen & Shapiro
Mr. Fletcher has particular expertise ranging from the taxation of mergers and acquisitions to international taxation... | Read More
Mr. Fletcher has particular expertise ranging from the taxation of mergers and acquisitions to international taxation to the resolution of tax controversies. He has counseled Fortune 500 companies as well as start-ups and middle-market businesses on all aspects of corporate and partnership taxation, including acquisitions and divestitures, joint ventures, and tax controversies.Close
Mr. Badyal counsels his clients through numerous forms of transactions and legal decisions including choice of entity,... | Read More
Mr. Badyal counsels his clients through numerous forms of transactions and legal decisions including choice of entity, entity formation, private placements, executive compensation, section 1031 exchanges, the formation or restructuring of complex joint ventures, and corporate mergers and other reorganizations. His practice includes both domestic and cross-border transactions. He also has extensive experience representing clients in tax audits and other controversies and has been an adjunct professor at the Thomas Jefferson School of Law.Close