IRS CCA 201501013: Navigating New & Heightened Scrutiny of Foreign Investment Fund Lending Income
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisors with the guidance necessary to survive IRS scrutiny in the context of foreign investment fund lending. The panel will cover in detail the application of the trade or business designation to foreign investment fund lending as well as effective use of safe harbors. Additionally, attendees will benefit from a discussion on reporting and loan origination rules.
Outline
- Context of CCA 201501013
- Trade or business designation
- Safe harbor rules
- Loan origination
- Reporting rules
- Surviving expanded audits
Benefits
The panel will answer the following questions:
- What considerations must be made when structuring foreign investment fund loans to avoid the trade or business designation?
- What are the best practices to maximize the benefits of available safe harbors?
- What techniques should be implemented when preparing for expanded tax audits within the context of foreign investment fund loans?
Faculty
Peter A. Glicklich
Partner
Davies Ward Phillips & Vineberg
Mr. Glicklich concentrates his practice in the taxation of corporate and international transactions. He advises... | Read More
Mr. Glicklich concentrates his practice in the taxation of corporate and international transactions. He advises public and closely held corporations and REITs in connection with their mergers and acquisitions, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing. For over 25 years, he has counseled North American and foreign-based multinationals and other institutions on their international and corporate tax concerns.
CloseSusan F. Klein
Partner
Akerman
Ms. Klein focuses her practice on tax matters relating to private international transactions and has extensive... | Read More
Ms. Klein focuses her practice on tax matters relating to private international transactions and has extensive experience advising individuals and companies with respect to their investments and business operations in Canada, Western Europe, and Israel. She also has experience representing foreign nationals and corporations in connection with U.S. investments, licensing operations, acquisitions, joint venture participations, and estate planning, and representing individuals and businesses in connection with foreign investments and operations.
CloseLeonard Schneidman
Managing Director
Andersen Tax
Mr. Schneidman has over 40 years of experience in international taxation. His work includes counseling clients on... | Read More
Mr. Schneidman has over 40 years of experience in international taxation. His work includes counseling clients on structuring and operation of private investment funds, advising high net worth foreign investors on U.S. investments and activities, helping U.S. and non-U.S. corporate clients with tax-efficient structuring of their business operations, and advising clients on the reporting of undisclosed income and/or foreign financial assets from offshore accounts through the IRS Offshore Voluntary Disclosure Program (OVDP) or Streamlined Filing Compliance Procedures, and Report of Foreign Bank and Financial Accounts (FBAR).
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