New IRS Final 863(b)(2) Regulations for Income Sourcing of Inventory Sales and Disposition of Partnership Interests
Determining Taxable Income, Books and Records Election, Adjusted Basis in Assets; Avoiding Double Taxation
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax professionals and advisers guidance on the IRS final Section 863(b)(2) income sourcing regulations. The panel will discuss key provisions of the final regulations, rules for determining the location or existence of production activity, measuring the adjusted basis of production assets, anti-abuse rules, and utilizing tax treaties to avoid double taxation. The panel will also discuss the impact of Sec. 863(b)(2) final regulations on sourcing for sales of purchased inventory under Sec. 865(e)(2) and other IRC provisions.
- Key provisions of Sec. 863(b)(2) final regulations
- Interplay with Sec. 865(e)(2) and other Code provisions
- Determining the location and existence of production activity
- Disposition of partnership interests
- Anti-abuse rules
- Best practices for taxpayers, tax counsel, and advisers
The panel will review and other key issues:
- What are the principal provisions and remaining issues of the Sec. 863(b)(2) final regulations?
- What are high priority taxpayer considerations for sales of inventory in light of the new regulations?
- What is the impact on the disposition of partnership interests?
- What are the rules for determining the location or existence of production activity for income sourcing purposes?
- How do you measure the adjusted basis of production assets?
- How do the anti-abuse rules apply?
- How can taxpayers utilize tax treaties to avoid double taxation?
Ms. Rensen is a managing director in KPMG’s Washington National Tax's International Tax practice. At KPMG,... | Read More
Ms. Rensen is a managing director in KPMG’s Washington National Tax's International Tax practice. At KPMG, she specializes in cross-border transactions involving complex international tax issues. Prior to joining KPMG, Ms. Rensen was an attorney in the IRS’s Office of Associate Chief Counsel (International), most recently as a special counsel. After the enactment of the Tax Cuts and Jobs Act, she focused on guidance implementing U.S. tax reform, including inventory sourcing, foreign-derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT). Earlier in her career, Ms. Rensen served as a tax associate in the tax controversy and transaction groups of the Washington D.C. office of Mayer Brown LLP. Prior to joining Mayer Brown, she served as an attorney-advisor to the Honorable Joseph R. Goeke of the U.S. Tax Court.Close
Julia M. Tonkovich
Ernst & Young
Ms. Tonkovich practice in the area of inbound taxation includes planning and compliance involving the Tax Cuts and Jobs... | Read More
Ms. Tonkovich practice in the area of inbound taxation includes planning and compliance involving the Tax Cuts and Jobs Act, the Foreign Account Tax Compliance Act, tax treaty qualification, chapters 3 and 4 withholding and information reporting, ruling requests and remediation solutions. Before joining EY, she had been an instructor at the University of Washington and served on the Washington, DC staff of Senator Max Baucus. Ms. Tonkovich earned her Bachelor of Arts from Stanford University, her Master of Arts from the University of Washington and her JD and LLM from Georgetown University Law Center.Close
Buy Live Webinar
Early Discount (through 12/18/20)
See NASBA details.
Buy Live Webinar & Recording
Includes special savings of $300 (through 12/18/20)
Live Webinar & Download
Live Webinar & DVD
$394 + $24.45 S&H