Legal Entity Restructuring: State Tax Implications
Analyzing Liquidation and Conversion Options to Achieve Tax Benefits
Recording of a 110-minute CPE/CLE webinar with Q&A
This course will provide tax executives and advisors with an analysis of the steps for leading a review of a company's business entities, focused on minimizing state taxes without undercutting the company's operations.
- Current trends in federal and state law and regs on legal entity restructuring
- Examples of some specific states
- Process for liquidating business entity or converting to disregarded entity
- C corporation
- Tax implications to consider in restructuring entities
- Effective tax rates calculation under FAS 109 and FIN 48
- Income tax nexus-triggering activities
- Dispersal of profits and losses among entities
- Use of NOLs
- Other issues
- Best practices for a coordinated approach to entity restructuring
- Led by corporate tax, or with tax in key position
- Working with other departments (e.g. legal, HR, accounting, finance)
The panel will address these and other important topics:
- Structural changes: What is involved in liquidating an entity or converting it to a disregarded entity?
- FAS 109/FIN 48 disclosures: Is your tax staff spending too much time on calculating effective tax rates because of outmoded entities?
- Nexus analysis: Could eliminating certain entities reduce your company's tax exposure in certain states?
- Losses and earnings: Are they imbalanced in some company entities, resulting in a needlessly high overall state income tax rate?
- Getting help from within: What other company departments need to be part of a business entity evaluation? How and when should they be brought into the effort?
Alston & Bird
He represents clients in state and local controversy and litigation matters, primarily those involving corporate... | Read More
He represents clients in state and local controversy and litigation matters, primarily those involving corporate income, sales and use, and property taxes. He also advises on state and local tax issues that arise during corporate and real estate transactions.Close
Steptoe & Johnson
Mr. Derdenger has more than 30 years of tax advisory experience, with a practice focused on federal, state and... | Read More
Mr. Derdenger has more than 30 years of tax advisory experience, with a practice focused on federal, state and local taxation in the realm of sales, income, employment and other taxes. He is active in IPT, TEI and other tax professional associations and chairs the Arizona Chamber of Commerce's Tax Policy Committee.Close
Michael A. Jacobs
He is a member of the firm's State Tax Group and his practice emphasizes state tax planning in business... | Read More
He is a member of the firm's State Tax Group and his practice emphasizes state tax planning in business transactions, including tax-free reorganizations, taxable acquisitions and state and local transfer taxes.Close