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New IRS Guidance for the Taxation of NFTs: Applicable Tax Rules, NFT Transactions, Issues...
May 31, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax counsel, accountants, and other advisers with a critical analysis of new IRS guidance regarding the tax treatment of non-fungible tokens (NFTs) and reporting obligations for taxpayers and investors. The panel will discuss recent IRS Notice 2023-27, treating NFTs... Read More

Tax Issues in Inbound and Outbound Transactions: Utilizing Partnerships to Maximize Tax Be...
Avoiding Landmines Under Current Tax Law, Deal Structures, Special Allocations
June 1, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will guide tax counsel and professionals on tax challenges and opportunities in utilizing partnerships for inbound and outbound transactions. The panelist will discuss key provisions impacting inbound and outbound transactions under current U.S. tax law, effectively using partner... Read More

IRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Ent...
Lowering U.S. Income Tax on Income From Eligible Foreign Entities by Electing Tax-Advantag...
June 6, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax advisers with guidance on the advantages and pitfalls of using the "check the box" election for foreign LLCs and disregarded entities. The panel will discuss the tax impact of specific elections of income from foreign disregarded entities and outline tax timing... Read More

Tax Issues for Cryptocurrency Investment Vehicles: U.S. Tax Law, Reporting, PTP Rules, ECI...
June 8, 2023 CLE, CPE, EA Live Webinar
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This CLE/CPE course will provide tax and other interested professionals with an in-depth analysis of key tax considerations and challenges for digital asset investment vehicles and hedge funds investing in cryptocurrency and other digital assets. The panel will discuss U.S. tax rules and obstacles f... Read More

IRC 754 Elections for Tax Counsel: Mastering Structuring Considerations of Basis Adjustmen...
Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections
June 15, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and partnership interests or property distributions; review the impact of the Section 754 election for in... Read More

IRS Clean Vehicle Tax Credit Eligibility: Inflation Reduction Act, New Section 30D Guidanc...
Criteria for Classification of Qualifying Critical Minerals, Battery Component Requirement...
June 20, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide taxpayers, manufacturers, advisers, and counsel a detailed analysis of available electric vehicle tax credits and the impact of the Inflation Reduction Act (IRA). The panel will discuss the amendments to Section 30D of the Internal Revenue Code, the processes for me... Read More

Taxation of U.S. Persons Owning Foreign Corporations: Strategies for Subpart F and GILTI I...
June 28, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will guide tax counsel and advisers on the implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law. The panel will discuss key tax provisions and regulations causing compliance issues for U.S. taxpayers,... Read More

IRC Section 355 Corporate Spin-Off Transactions: Optimizing Tax Treatment in Divestitures
July 6, 2023 CLE, CPE, EA Live Webinar
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This course will provide tax counsel with a practical guide to the key tax considerations in structuring corporate spin-offs and carve-outs. The panelist will examine key legal, business and tax considerations for deal structuring, economic terms, due diligence, asset transfers, and more. Read More

Tax Implications of Student-Athlete NIL Deals and Collectives: Federal and State Tax Issue...
July 11, 2023 CLE, CPE, EA Live Webinar
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This CLE/CPE webinar will provide tax professionals guidance on the key tax considerations for student-athlete name, image, and likeness (NIL) deals and NIL collectives. The panel will discuss the applicable rules and regulations for NIL deals and entities engaging in these transactions, federal and... Read More

IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Tax Savings
Navigating Applicable IRC Sections, Formation and Qualification Issues, and Capturing Maxi...
July 27, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax counsel and advisers with the guidance necessary to maximize the powerful tax benefits of the interest charge domestic international sales corporation (IC-DISC). The panel will review the complex requirements of applicable IRC sections, formation best practices,... Read More

Tax Issues With M&A Representations, Warranties, and Indemnifications: Reps and Warranty I...
August 1, 2023 CLE, CPE, EA Live Webinar
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This CLE/CPE course will guide tax counsel and advisers on the tax ramifications of representations, warranties, and indemnification provisions in mergers and acquisitions. The panel will discuss critical tax considerations for indemnification payments and losses and representation and warranty insu... Read More

Partnership Tax Compliance and Navigating IRS Examinations: Reporting Requirements, Best P...
Reporting International Transactions, Schedules K-2 and K-3, LB&I Initiatives, Tax Plannin...
August 3, 2023 CLE, CPE, EA Live Webinar
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will guide tax professionals in navigating partnership tax compliance issues and IRS examinations. The panel will discuss reporting requirements for international transactions, Schedules K-2 and K-3 for reporting partners' income, deductions, and credits from foreign activity, a... Read More

Mastering Subpart F Tax Compliance: Key Reporting Requirements on Forms 5471 and 1118
August 15, 2023 CLE, CPE, EA Live Webinar
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This CLE/CPE course will provide tax professionals with an in-depth discussion of reporting Subpart F income challenges. The panel will discuss the proper methods of determining the Subpart F income earned by U.S. persons that qualify as U.S. shareholders of controlled foreign corporations (CFCs) an... Read More

IC-DISC vs. FDII Tax Incentives: Determining When a Taxpayer Can Use Both Methods to Maxim...
May 25, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax counsel and advisers guidance on utilizing the Interest-Charge Domestic International Sales Corporation (IC-DISC) and Foreign-Derived Intangible Income (FDII) export tax incentives and circumstances where both may be used by taxpayers. The panelist will discuss... Read More

Tax Issues for Family Offices: Structuring Options, Income Tax Planning, Allocations, Inve...
May 23, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax attorneys and professionals an in-depth analysis of key tax considerations for family offices under current tax law and discuss the potential impact of proposed legislation. The panel will discuss cases and legislation impacting the family office industry, consid... Read More

Partnership Exchanges Under Current Tax Law: Structuring "Drop and Swap" and "Mixing Bowl"...
May 18, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax advisers with knowledge and tools to advise partnership clients converting to a tenancy-in-common form of real estate ownership. Tax advisers may recommend such a conversion in contemplating a future sale of property or creating a master limited liability company... Read More

Tax Issues for Airplane Purchases: Planning Strategies, Complexities Under Current Tax Law
May 16, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will outline guidance to tax attorneys and advisers on the applicable tax rules and key considerations for business aircraft purchases and ownership. The panel will discuss available planning options for purchases and ownership, reduced or eliminated tax deductions, and opportuni... Read More

S Corp Redemptions: Characterization, Tax Consequences, Application of Sections 302 and 30...
Sale or Exchange vs. Distribution, Evaluating Conversion to a C Corp, Available Tax Planni...
May 11, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax counsel and advisers with a specific and practical guide to navigating the tax rules that apply to the redemption of S corporation interests. The panel will discuss characterization as a sale or exchange versus distribution, tax consequences associated with such... Read More

Tax Strategies for Limited Partner Investors in Private Investment Funds
Avoiding Tax Traps Through Side Letters and Other "Hidden" Agreements
May 9, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax counsel and advisers with a detailed guide to the tax issues of various types of private investment funds, including private equity, venture capital, and real estate funds. The panel will discuss the tax implications of various fund structures, identify potentia... Read More

Tax Planning for Content Creators, Social Media Influencers, and Online Entrepreneurs
Key Tax Issues, Structuring Tax Efficient Entities, Reporting and Maximizing Deductions, H...
May 2, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax professionals a detailed analysis of tax challenges and planning techniques for content creators, social media influencers, and online entrepreneurs. The panel will discuss complex tax planning challenges for online entrepreneurs, planning tips for certain asset... Read More

Structuring Qualified Opportunity Zone Investments for Family Offices and Private Clients
April 27, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will give tax professionals an in-depth analysis of the Qualified Opportunity Zone (QOZ) tax incentive program under Section 1400z-2 and applicable regulations (QOZ Tax Program) and how family offices and private clients should consider structuring QOZ investments. The panelist w... Read More

Tax Considerations for Up-C Structures and Transactions: Tax Receivable Agreements, Equity...
April 18, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide an in-depth analysis of key tax considerations for Up-C structures and transactions involving Up-Cs. The panel will discuss legal and tax challenges unique to Up-C structures, terminating or amending the tax receivable agreements, rolling over existing equity intere... Read More

Tax Implications of Cryptocurrency Validation Rewards: Mining and Staking
IRS Guidance to Date, Identifying Taxable Events and Traps, Valuation, Classifying DAOs, H...
April 13, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax counsel, accountants, and other advisers with a critical analysis of the correct U.S. federal income tax treatment of different types of cryptocurrency block rewards--specifically newly minted tokens and other rewards created or received from the "mining" or "st... Read More

Tax Issues and Planning Considerations for U.S. Executives: Pitfalls to Avoid and Best Pra...
Deferred Compensation, Doctrine of Constructive Receipt, Section 83, Tax Consequences of E...
April 4, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax professionals and attorneys guidance on critical tax issues and available planning techniques for U.S. executives. The panel will discuss income tax rules applicable to U.S. citizens, resident and nonresident aliens, application of Section 409A and Section 83, t... Read More

IRS Final Regulations on FIRPTA Exemption for Qualified Foreign Pension Funds
Modification of the 85% Test, New and Revised Definitions, Withholding Rules, and More
March 21, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax counsel and advisers guidance on notable changes and key issues of final IRS and Treasury qualified foreign pension funds regulations regarding gains or losses attributable to dispositions of U.S. real property interests. The panel will discuss modifications to... Read More

Equity Compensation Grants in Partnerships and LLCs: Overcoming Tax Challenges and Key Pla...
Carried Interest, Section 83, Profits vs. Capital Interests, Options and Phantom Equity, a...
March 14, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax counsel and advisers with a detailed analysis of the tax implications of equity compensation grants in partnerships and LLCs. The panel will discuss profit versus capital interests, phantom equity, the application of Section 83, carried interest, and best tax pla... Read More

2023 IRS Enforcement Update: Key Areas of Focus for Examinations, Audits, and Criminal Cas...
Abusive Tax Avoidance Transactions, Crypto-Related Audits, Criminal Digital Asset Cases, T...
March 9, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide guidance to tax professionals on the 2023 IRS enforcement initiatives and key issues for taxpayers. The panel will discuss recent IRS investigations, abusive tax avoidance transactions, increased crypto-related audits, criminal digital asset cases, transfer pricing,... Read More

Planning for the Rescue Capital Wave of 2023: Tax and Non-Tax Considerations for Rescue Ca...
March 7, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide holistic guidance on key tax planning issues in rescue capital transactions and discuss tax planning considerations for parties involved in such transactions, including (i) modifications to capital stacks and resulting changes to allocations and distribution rights... Read More

Tax Implications of the Inflation Reduction Act: Corporate AMT, Stock Repurchase Excise Ta...
March 2, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will guide tax counsel and advisers on critical provisions of the Inflation Reduction Act of 2022 (the Act) and their impact on specific corporate transactions, operations, and tax planning. The panel will discuss the new corporate alternative minimum tax, the excise tax on stoc... Read More

Tax Issues in Sale of Partnership and LLC Interests: Structuring the Purchase Agreement, N...
February 28, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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The CLE/CPE course will review the tax issues involved with structuring purchase agreements for partnership or LLC interests. The panelist will address allocation of income gains and losses, allocation of the purchase price, payment terms in the purchase agreement, and the impact of current tax law... Read More

Tax Issues for Airplane Purchases: Planning Strategies, Complexities Under Current Tax Law
February 23, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

This CLE/CPE course will outline guidance to tax attorneys and advisers on the applicable tax rules and key considerations for business aircraft purchases and ownership. The panel will discuss available planning options for purchases and ownership, reduced or eliminated tax deductions, and opportuni... Read More

Taxation of Intellectual Property: IRC 1235, FDII and GILTI, Taxation of Moving IP Offshor...
February 15, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax counsel with practical guidance on the taxation of intellectual property (IP) assets under current tax law. The panel will discuss the tax treatment of patents, design models or other IP assets created by individual taxpayers, Section 1221 and obtaining the benef... Read More

Foreign Financial Institution Reporting: FFI Agreement, Issues for U.S. Taxpayers, Due Dil...
February 9, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a detailed guide to preparing and filing a foreign financial institution (FFI) agreement. The panel will describe the FFI designation in depth, outline the due diligence and reporting requirements of a participating FFI, and discuss the... Read More

Tax Treatment of Guaranteed Payments to Partners: Impact of IRC 199A, Section 707 Payments...
Maximizing QBI Benefits and Structuring Payments to Service Providing Partners Under Curre...
January 24, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE webinar will provide tax counsel with a critical analysis of the impact of the Section 199A qualified business income (QBI) deduction on the tax treatment of guaranteed payments to partners. The panelist will discuss the default treatment of payments for services to a partner under Sect... Read More

Tax Issues in Transferring LLC and Partnership Interests
Navigating the Complex IRS Rules for Buying, Selling, or Redeeming Partnership Interests
January 19, 2023 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions. Read More

Taxation of Cannabis: Overcoming Tax Challenges in Cannabis Business Operations, Key Plann...
Entity Selection, Gross Income Inclusion, Impact of Tax Reform, Effect of Section 280E, IR...
January 17, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax counsel and advisers guidance on tax and related issues for businesses engaged in the cannabis industry. The panel will discuss critical federal and select state tax rules impacting cannabis businesses, recent tax court decisions, Section 280E, forfeiture, and ba... Read More

U.S. GILTI Anti-Deferral Rules and Tax Compliance: Reporting Issues, Navigating Forms 5471...
January 11, 2023 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global intangible low-taxed income (GILTI). The panel will discuss how GILTI is calculated and key tax GILTI reporting issues involving IRS Forms 5471, 899... Read More

Structuring Redemptions of Partnership and LLC Interests: Issues Unique to Liquidating Dis...
IRC 754 Elections, Section 736(b) Payments, Character and Timing of Gain, Installment Sale...
December 14, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with specific and practical guidance in navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss common pitfalls and uncertainties under current tax law and outline best practices to struct... Read More

GILTI High-Tax Exclusion: Sections 951A and 954 Rules for Individual and Non-C Corporation...
Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GI...
December 7, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals on the challenges of the global intangible low-taxed income (GILTI) provisions under current tax law and the recent GILTI high-tax exception. The panel will discuss IRS final regulations and the high-tax exception, treatment of controlled foreign corp... Read More

U.S. Tax Planning for Foreign Nationals: Sourcing of Income, Exemptions, Tax Treaties, and...
November 29, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals guidance on key U.S. tax planning strategies available to foreign nationals and pitfalls to avoid. The panel will discuss key considerations for resident and nonresident aliens for U.S. tax purposes, sourcing of income and challenges that disrupt ta... Read More

Tax Treatment of Non-Fungible Tokens: Applicable Tax Rules, Characterization Issues, Crypt...
November 9, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, accountants, and other advisers with critical analysis, non-fungible token (NFT) tax treatment, and reporting obligations for taxpayers and investors. The panel will discuss the difference between NFTs and other cryptocurrencies, IRS rules, and define pr... Read More

Taxation of Decentralized Finance Transactions: IRS Guidance, Tax Issues for DeFi Lending,...
November 3, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax counsel, accountants, and other advisers with a critical analysis of IRS tax treatment of decentralized finance (DeFi) transactions. The panel will discuss the IRS' position on the tax treatment of DeFi companies and platforms, critical tax considerations for U.... Read More

Structuring Tiered Partnerships: Advanced Tax Planning Strategies, Avoiding Tax Traps
Treatment of Allocations and Deductions, Application of Sec. 704 and 743
October 25, 2022 CLE, CPE, EA CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will guide tax counsel on the available tax planning strategies in structuring tiered partnerships. The panel will discuss tax considerations for structuring tiered partnerships, treatment of allocations and deductions, the impact of tax reform and IRS partnership audit rules, th... Read More

Navigating the IRS Penalty Abatement Procedures for Foreign Information Reporting Noncompl...
Requesting Penalty Abatements for Failure to File Forms 5471, 5472, FATCA, and FBAR
October 19, 2022 CLE, CPE CLE On-Demand, Download
This program is included with the Strafford CLE Pass. Click for more information.
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This CLE/CPE course will provide tax attorneys and accountants with a detailed discussion of best practices for requesting relief of IRS penalties as a result of failing to timely file required international information forms such as Forms 5471, 5472, 3520, 3520-8858, 8865, 926, and the FBAR. The pa... Read More

Handling Cannabis Tax Examinations: Sec. 280E, Audits, IRS Guidance, Reporting Requirement...
October 11, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers on effective methods in handling IRS cannabis tax examinations for businesses engaged in the cannabis industry. The panel will discuss critical federal and select state tax law provisions impacting marijuana businesses, essential items of focus... Read More

Tax Planning Strategies for S Corporation Mergers and Acquisitions
Asset vs. Stock Sales, 338(h)(10) and 336(e) Elections, Qualifying for Installment Sales T...
September 28, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals guidance on tax challenges in S corporation mergers and acquisitions and available tax planning techniques. The panel will discuss key legal and tax considerations for both the buyers and sellers, the pros and cons of asset sales versus stock sales,... Read More

Tax Treatment of Carried Interest: Final IRS Regs, Strategies for Tax, Private Equity, Rea...
IRC Section 1061, Capital Contributions, Transfers to Unrelated Parties, Special Allocatio...
September 22, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers on the current tax law's impact on the treatment of carried interest and available planning opportunities. In addition, the panel will discuss IRS final regulations, the application of Sec. 1061, Sec. 1231 property, implications of related part... Read More

Reinstatement of the Superfund Excise Tax: Key Issues and Action Items for Manufacturers,...
Taxable Substances, Actions Triggering the Tax, Calculations, Tax Returns and Payments, Re...
September 20, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals with an in-depth analysis of the critical issues and challenges of the reinstatement of the Superfund Excise Taxes for manufacturers, producers, and importers. The panel will discuss applicable tax rules, taxable chemicals and taxable substances, ac... Read More

Tax Issues for Rollover Equity in M&A Transactions: Key Considerations for Buyers and Sell...
September 8, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals with an in-depth analysis of key tax issues of equity rollover in mergers and acquisitions. The panel will discuss critical provisions and structuring considerations for equity rollovers in M&A transactions, tax-free mergers, holding company structu... Read More

Multistate Tax Issues for Pass-Through Entities: State Recognition Rules, Taxation of S Co...
August 31, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers to resolve complex tax questions confronting pass-through entities with a presence in more than one state. Our panel will brief attendees on state recognition rules and other complexities that apply to multistate S corps, LLCs, and partnerships... Read More

Asset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting, and Structuring Techniqu...
August 25, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide practical guidance on best practices for tax counsel advising clients buying or selling a business and the tax ramifications of structuring the transaction as an asset sale vs. a stock sale. Each structure has distinct advantages and disadvantages, and tax counsel mu... Read More

Section 336(e) Elections: Tax Basis Step-Up Through Deemed Asset Sale Treatment
Structuring Qualifying Stock Dispositions for Partnership and Private Equity Acquirers and...
August 18, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax advisers with a thorough and practical guide to utilizing a Section 336(e) step-up election in the disposition of a target corporation. The panel will contrast the Section 336(e) election with the election available under Section 338(h)(10), outline the requireme... Read More

Taxation of Foreign Branches Under Current Tax Law: Qualified Business Units, Foreign Tax...
August 17, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax counsel and advisers with an in-depth analysis of the tax treatment of foreign branches of U.S.-based companies under current tax law. The panel will discuss what constitutes a foreign branch, reporting obligations, foreign tax credits, recent 267A anti-hybrid r... Read More

IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Exami...
August 11, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax professionals and advisers with an in-depth discussion of the IRS examination of taxpayers living abroad. The panel will focus on Section 965 transition tax, exit tax, critical issues for non-filers, guide tax practitioners through the examination process, and e... Read More

Nonresident Alien Tax Compliance: Challenges and Planning Techniques for Tax Professionals
IRS Compliance and Enforcement, ECI vs. FDAP Income, Reporting Requirements, Exemptions, D...
August 3, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and compliance professionals guidance on the rules, reporting requirements, and available tax planning mechanisms for U.S. nonresident alien taxpayers. The panel will offer approaches for determining taxpayer classification, identifying and reporting inco... Read More

Gain on Sales of U.S. Partnership Interests by Foreign Partners: Sections 864(c)(8) and 14...
Determining and Reporting Gain on Effectively-Connected U.S. Source Income
July 20, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel will discuss new and significant changes to international taxation relating to the disposition of U.S. partnership interests owne... Read More

Understanding Opportunity Zone Tax Incentives in Light of New Congressional Oversight and...
July 13, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax counsel and advisers with a detailed analysis of the qualified opportunity zone (QOZ) tax incentives in light of new congressional oversight and the recent Treasury Inspector General for Tax Administration (TIGTA) report. The panel will discuss recent developmen... Read More

Domesticating Individually Owned Controlled Foreign Corporations Under Current Tax Law
Restructuring CFCs for U.S. Taxpayers, Mitigating Tax Liability, Section 962 Election, Tra...
July 6, 2022 CLE, CPE CLE On-Demand, Download
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This course will guide tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually owned controlled foreign corporations (CFCs) under current tax law. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investme... Read More

New Subpart F and PFIC Regulations for U.S. Investors and Domestic Funds
Calculating Subpart F and PFIC Inclusions, Partner-Level PFIC Elections, IRC Sec. 1248, CF...
June 22, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers guidance on recently released final and proposed regulations for calculating Subpart F and passive foreign investment company (PFIC) inclusions. The panel will discuss key provisions of the final and proposed rules, the impact to U.S. investo... Read More

Navigating IRS Scrutiny of R&D Tax Credits: Qualified Research Activity, Expenses, Researc...
June 1, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will guide tax professionals and advisers on navigating IRS scrutiny and challenges to the R&D tax credit for small and large businesses and international taxpayers. The panel will discuss the recent IRS crackdown on documentation of research credit claims, managing IRS audits,... Read More

Puerto Rico Act 60 Tax Exemptions: IRS Examination and Audits, Key Issues for Individual a...
Treatment of Puerto Rico-Sourced Income, Puerto Rico Act 60 (formerly Act 20 and Act 22) B...
May 17, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide persons who have taken advantage of Puerto Rico Act 60 (formerly Act 20 and 22) and their tax advisers with guidance on managing an IRS examination and audit on grantees. The panel will also discuss the favorable treatment for Puerto Rico-source income and areas of l... Read More

Federal and State Tax Residency Issues: Navigating IRS Examination Guidance, State Regulat...
May 12, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax professionals guidance on key federal and state tax residency rules and planning considerations for taxpayers. The panel will discuss the importance of both citizenship and residence in determining tax liabilities of individuals, challenges for remote workers, t... Read More

Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, For...
Evolution of "Non-Willful" Standard, Identifying Compliance Issues, District Court and Cou...
May 11, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of effective methods and challenges in resolving international tax compliance issues and disputes. The panel will discuss critical tax compliance issues stemming from Forms 3520/3520-A and 5471, navigating FBAR assessment... Read More

Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations
Tax Treatment of Digital Currency, Exchange Transactions, Investments, Drop-Ins, Hard Fork...
May 4, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, accountants, and other advisers with a critical first look at recent IRS enforcement actions on taxpayer compliance and reporting obligations for cryptocurrency transactions. The panel will discuss the IRS position on the tax treatment of cryptocurrency,... Read More

Structuring Waterfall Provisions in LLC and Partnership Agreements
Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences
April 27, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide corporate and tax counsel on the various methods of structuring waterfall distribution provisions in LLC and partnership agreements. The panel will examine a variety of economic and tax considerations such as timing and types of distributions (including tax distributio... Read More

IRS Final Carried Interest Regulations: Significant Tax Rule Changes and Planning Opportun...
April 21, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers on the IRS final regulations, the tax treatment of carried interest, and available planning opportunities. The panel will discuss the application of Sec. 1061, modifications to the capital interest exception, applicable partnership interests (A... Read More

Tax Treatment of S Corp Distributions: Income and Deduction Rules, Basis, Salary vs. Incom...
April 6, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax professionals an in-depth analysis of the tax treatment of S corporation distributions and key planning techniques for shareholders. The panel will discuss key factors in determining the taxability of distributions of cash and property, shareholder loans, salary... Read More

Qualified Opportunity Zones and Tax Credits: IRS Regulations, Capital Gain Deferral Mechan...
New Markets Tax Credit, Step-Up in Basis, Appreciation Exclusion, Tax Planning Strategies...
March 30, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a detailed analysis of the qualified opportunity zones tax incentive mechanism provided under current tax law. The panel will discuss final IRS regulations for investors, recent amendments, new markets tax credit, energy tax credits and... Read More

Advanced Tax Strategies in Structuring Private Equity and Real Estate Investment Funds: Ba...
March 24, 2022 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with advanced guidance on structuring private equity and real estate investment funds. The panel will discuss critical considerations in light of proposed new tax laws and address fund manager and fund investor issues. Read More

IRS Foreign Tax Credit Regulations and Recent Guidance: New Income-Sourcing Standard, Digi...
March 23, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and recently issued guidance. The panel will discuss new income-sourcing standards, the impact on digital services taxes, rules relating to foreign-derived intangible income (FDI... Read More

FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets
Unraveling Foreign Asset and Income Reporting Obligations, Navigating Available Voluntary...
March 16, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide counsel and tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets and assisting clients with developing programs that provide workable solutions. Read More

Taxation of Digital Asset Transactions: Impact of New Infrastructure Bill, Cash Transactio...
March 3, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE webinar will provide tax counsel and advisers with a detailed analysis of the taxation of digital asset transactions under current tax law and new rules under the recently enacted Infrastructure Investment and Jobs Act. The panel will discuss the impact of the new Act, applicable IRS ta... Read More

IRC 732(d) Partnership and LLC Basis Adjustments for Tax Counsel
Mastering Elective and Mandatory Basis Adjustments on Distributed Property Absent a Partne...
March 1, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with comprehensive guidance on navigating the rules governing mandatory Section 732(d) basis adjustments on distributed property by partnerships where there is no Section 754 election in place. The panel will discuss the application challenges surrounding... Read More

Tax Considerations for REITs and RICs: Recent IRS Guidance, Distributions, Reporting Requi...
February 24, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with an in-depth analysis of key tax considerations and related issues for real estate investments trusts (REITs) and regulated investment companies (RICs). The panel will also discuss recent developments including Revenue Procedure 2021-53 p... Read More

Partnership Allocations of Rehabilitation, New Market, and Other Tax Credits: Navigating C...
February 23, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a comprehensive guide to provisions allocating tax credits within a partnership agreement. The panel will discuss what criteria to evaluate in determining whether any tax credit allocation will be respected and go into detail on provisions for alloca... Read More

U.S.-UK Tax Planning and Traps to Avoid: Reporting Issues, Tax Treaties, Passive Income, P...
February 10, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a practical guide into some issues which arise in relation to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in the United Kingdom, as well as UK citizens with U.S. tax reporting obli... Read More

Structuring Contributions of Appreciated Property to Partnerships: Avoiding Tax Recognitio...
January 27, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a comprehensive guide to the tax consequences of contributing appreciated property to a partnership or multi-member LLC. The panel will discuss the specific tax treatment of appreciated property's contribution with debt, depreciation allocation, both... Read More

Tax Planning for Real Estate Professionals: Passive Activity Rules, Material Participation...
January 12, 2022 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide attendees with an in-depth analysis of essential tax planning techniques and challenges for real estate professionals. The panel will discuss the criteria to be a real estate professional for tax purposes, passive activity rules, material participation tests, aggrega... Read More

Tax Issues in Transferring LLC and Partnership Interests
Navigating the Complex IRS Rules for Buying, Selling, or Redeeming Partnership Interests
December 16, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions. Read More

Voluntary Disclosure of Foreign Assets: Current Challenges for Noncompliant U.S. Taxpayers
Options for Compliance, Avoiding Penalties and Potential Criminal Prosecution
November 23, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide counsel and tax advisers with guidance on available options for reporting foreign assets of noncompliant U.S. taxpayers. The panel will discuss Foreign Bank Account Report (FBAR) requirements, alternative compliance options after the IRS' termination of the Offshore... Read More

Taxation of Foreign Pensions: Application of IRC 402(b) and Avoiding Penalties for Noncomp...
Tax Rules Governing Foreign Pension Accounts, Foreign vs. U.S. Qualified Plans, Use of Tax...
October 28, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and ERISA attorneys a detailed analysis of the tax rules governing foreign pension accounts, with a specific focus on avoiding penalties for noncompliance. The webinar will go beyond the basics to offer useful practice pointers on the application of IRC 4... Read More

Interest Deduction Limitations Under Section 163(j): IRS Final Regs, State Tax Issues, Par...
Rules for Computing ATI, Determining Deduction Cap, Special Carryover and Transition Rules...
October 26, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will address recent final IRS regulations on interest deduction limitations under Section 163(j). The panel will discuss the impact of the regulations on partnerships and CFCs, rules for computing ATI and determining the deduction cap, special carryover and transition rules, and... Read More

U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FATCA/FBAR R...
October 21, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a thorough and practical guide into the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in India, as well as India citizens with U.S. tax reporting obligations. The panel will discuss U.S.... Read More

Section 199A: Deductions, Limitations, Complexities and Opportunities for Pass-Through Ent...
Determining Qualified Business Income, Loss Carryover, Reformation Considerations, and Mor...
October 7, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, accountants, and other advisers with an in-depth understanding of Section 199A and the mechanics of calculating and claiming the qualified business income deduction. The panel will discuss the strict rules, requirements, and limitations of IRC Section 19... Read More

Structuring Redemptions of Partnership and LLC Interests: Issues Unique to Liquidating Dis...
IRC 754 Elections, Section 736(b) Payments, Character and Timing of Gain, Installment Sale...
October 5, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with specific and practical guidance to navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss common pitfalls and uncertainties under current tax law and outline best practices to struct... Read More

Foreign Tax Credit Limitations Under Section 904: IRS Regulations and Guidance for Tax Cou...
Allocations, Apportionment, Limitations Under Section 904(b)(4), Impact of GILTI, Carryove...
September 21, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a critical analysis of IRS foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the regulations, additional "buckets" of foreign income grouping, allocation and apportionment rules, limitations under Sectio... Read More

Claiming the R&D Tax Credit: IRS Rules, Substantiation of QRAs and QREs, Offsetting Payrol...
September 16, 2021 CLE, CPE, EA CLE On-Demand, Download
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This course will provide tax counsel and advisers a thorough and practical guide to Section 41 Research and Development (R&D) Income Tax Credits. The panel will identify activities treated as qualified research activities (QRAs), offer guidance on documenting and claiming the credit, outline strateg... Read More

IRS Promoter Investigations, Enforcement Actions, and Penalties: Syndicated Conservation E...
September 14, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals through new IRS enforcement actions focused on promoters of syndicated conservation easements and micro-captive arrangements. The panel will discuss recent IRS investigations of promoters of what they determine as abusive tax avoidance transactions, n... Read More

Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easeme...
August 24, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide guidance to tax counsel and advisers on critical tax issues concerning conservation easement transactions. The panel will discuss critical elements in structuring conservation easement transactions to minimize IRS assessments and audits, recent IRS enforcement action... Read More

Capital Gains Planning for Real Estate Transactions: Allocations, Entity vs. Asset Purchas...
August 17, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a thorough and practical guide to structuring and tax planning strategies specifically for maximizing favorable capital gains tax treatment for real estate transactions. The panel will outline best practices for determining the purchasin... Read More

Tax Issues for Secondary Sales of Private Funds: Transfer Restrictions, Fund Structures, T...
August 12, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide guidance to tax counsel and advisers on critical tax considerations for secondary sales of interests in private funds. The panel will discuss tax and fund structuring challenges impacting the buyers, sellers and the fund, transfer restrictions, tax elections, allocat... Read More

Tax Issues for Foreign Investors in Qualified Opportunity Zones: Deal Structures, Tax Rule...
July 22, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals guidance on tax challenges for non-U.S. investors in qualified opportunity zones (QOZs). The panel will discuss recent U.S. tax law developments and IRS regulations impacting foreign investors, legal requirements, and processes to achieve tax benefi... Read More

Structuring U.S. Governed Law Trusts Classified as Foreign Trusts for U.S. Tax Purposes
July 15, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide a deep dive into the planning opportunities and reporting requirements for U.S.-based trusts that must file as non-domestic trusts for income tax purposes. The panel will discuss what constitutes "substantial decisions by non-U.S. persons" for trusts, structuring con... Read More

Special Purpose Acquisition Companies: Tax Structures, PFIC, QEF Election, and More
July 8, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of key tax challenges for special purpose acquisition companies (SPACs). The panel will discuss tax issues upon formation, tax considerations for structuring transactions, and key tax challenges for domestic and foreign i... Read More

Removing PFIC Taint on Foreign Investments Through Subsequent Year QEF Elections
New Final PFIC Regulations and Navigating PFIC Rules of IRC Sections 1291-1298
June 30, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax attorneys and counsel with a practical guide to removing the "taint" of foreign investments treated as passive foreign investment companies (PFICs). The panel will discuss new final and proposed PFIC regulations, the complex qualified electing fund (QEF) election... Read More

Blocker Structuring Under Current U.S. Tax Law: Key Considerations for U.S. Venture Funds...
June 17, 2021 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and private investment professionals with a practical guide to structuring investments by private equity and venture capital funds (PEVC funds) in a manner that seeks to address the various tax sensitivities of PEVC fund investors. Read More

Reporting Requirements of the Corporate Transparency Act of 2021: Compliance Challenges, B...
June 9, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide corporate, real estate and tax attorneys and advisers guidance on the compliance and reporting requirements of the new Corporate Transparency Act of 2021 (CTA). The panel will discuss key provisions of the CTA, determining what companies are "reporting companies" and... Read More

Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance
Recognizing When the IRS Will Deem an International Tax Information Filing as Not "Substan...
June 8, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a practical discussion of IRS International Practice Unit (IPU) guidance on what constitutes "substantial compliance" in filing Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. The panel will de... Read More

Section 385 Regulations on Related-Party Debt
Avoiding Reclassification of Debt to Equity, Structuring Intercompany Debt Instruments to...
June 3, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide critical analysis of the IRS regulations under Section 385 to reclassify certain related-party debt as equity for U.S. tax purposes. The panel will discuss the regulations' scope, examine what types of structures and transactions are subject to reclassification as eq... Read More

New IRS Final Section 451(b) and 451(c) Regulations: Rules for Income Recognition and Adva...
All-Events Test for Gross Income, Cost Offset, Multi-Year Contract Issues, Contracts With...
June 1, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals and advisers a detailed analysis of IRS final regulations and new rules under Sections 451(b) and 451(c) for the timing of income recognition and advance payments. The panel will discuss the challenges and opportunities for taxpayers under the final... Read More

Form 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abateme...
Establishing Reasonable Cause Exceptions, Appeals Prior to Payment, Collection Due Process...
May 20, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a comprehensive and practical guide to a deep exploration into the reporting regime for U.S. taxpayers' ownership of foreign trust assets on IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts.... Read More

Critical Tax Considerations for M&A Transactions: NOL Limitations, Deemed Income, Withhold...
May 18, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide counsel and tax professionals on new tax provisions that could substantially affect the structuring, pricing, and financing of mergers and acquisitions. The panel will discuss critical changes to the tax law, certain tax-related aspects of M&A negotiations requiring ca... Read More

Tax Implications of the New American Rescue Plan Act: Key Considerations for Individual an...
Planning Opportunities and Challenges for Taxpayers Under the Biden Administration Stimulu...
May 13, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals and advisers with guidance on the new American Rescue Plan Act. The panel will discuss essential next steps for taxpayers, obtaining the employee retention payroll tax credit, key issues for self employment taxes, rules for NOLs, and other key items... Read More

Final IRC 162(f) and 6050X Regulations: Tax Treatment of Settlements and Judgments, Requir...
April 28, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals guidance on key provisions of recently issued final IRC 162(f) and 6050X regulations. The panel will discuss applying the final regulations to fines, penalties, and other amounts, along with the requirements and exceptions. The panel will also discu... Read More

Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the A...
April 20, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign information reporting forms, their ass... Read More

State and Local Tax Claims in Ch. 11 Bankruptcy: Challenges and Strategies for Attorneys a...
Key Bankruptcy Provisions for SALT Claims and Objections; Court Authority to Determine Cla...
April 1, 2021 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will provide attorneys and tax professionals guidance for managing state and local tax agency claims in Chapter 11 bankruptcy proceedings. The panel will discuss challenges for state and local tax practitioners, applicable bankruptcy rules, proof of claims and objections, negotia... Read More

U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulati...
Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Pro...
March 25, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e). Read More

Structuring Foreign Investment in U.S. Real Estate: Entity Selection and Transaction Struc...
FIRPTA, Determining Individual vs. Entity Ownership Structures, Achieving Optimal Tax Trea...
March 16, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. real estate. The panel will outline best practices for determining the purchasing entity and review tax planning opportunities in structurin... Read More

Tax Implications of Liquidating Trusts for Bankrupt and Distressed Companies
Characterization of the Trust, Income Taxes, Net Operating Losses, Filing Requirements
March 11, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers with an in-depth analysis of tax implications of liquidating trusts for bankrupt or distressed companies. The panel will discuss key tax considerations in forming liquidating trusts to settle certain debts, collecting and holding assets,... Read More

IRC 831(b) Micro-Captives: Avoiding IRS Scrutiny, Diversification Requirements, Effective...
February 25, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, and advisers with practical tools and guidance to ensure that clients utilizing micro-captive insurance companies are fully compliant with IRC Section 831(b) rules to preserve legitimate tax deduction of premiums. The panel will discuss tax benefits and... Read More

Net Operating Loss Planning Under Current Tax Law: Planning Techniques and Challenges
Impact to Both Corporate and Noncorporate Taxpayers, Timing Issues and Other Consideration...
February 10, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers on key tax rules for net operating losses (NOLs) and their impact on tax planning for taxpayers. The panel will discuss changes to the NOL carryback and carry-forward rules and limitations under current tax law, its effect on leveraging reduced... Read More

Maximizing the FDII Deduction for U.S. Exported Property and Services: Determining Foreign...
January 6, 2021 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers guidance on the rules and reporting requirements for Section 250 tax deduction for foreign-derived intangible income (FDII). The panel will discuss new IRS regulations, identifying deduction-eligible income (DEI) and foreign-derived deduction... Read More

BBA Audit Procedures for Tax Counsel: IRS Enforcement Actions, Pitfalls to Avoid, Successo...
December 1, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals and advisers guidance on Bipartisan Budget Act (BBA) audit procedures and rules and recent IRS enforcement actions and guidance. The panel will describe the partnership audit processes in detail, outlining the changes that facilitate IRS audits of p... Read More

Tax Planning Issues for U.S. Expatriation: Minimizing the IRC 877A Exit Tax
Determining Covered Expatriates, Navigating the Mark-to-Market Tax on Unrealized Gains, Re...
November 18, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes. The panelist will discuss the impact of new tax law on expatriation planning techniques, critical challenges under Section 877A, and guidance o... Read More

Repatriation Tax Audits: Managing IRS Enforcement Actions and Strategies for Tax Professio...
Calculating Section 965 Inclusions, IRS Regulations, Cash vs. Non-Cash or Non-Liquid Asset...
November 4, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and professionals an in-depth analysis of the challenges of repatriation tax audits and techniques for handling IRS enforcement actions. The panel will discuss recent IRS initiatives and standards for the repatriation of foreign sourced income, calculatin... Read More

High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actio...
October 22, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide counsel and tax advisers with guidance on available options for handling high income non-filers and navigating IRS collection issues. The panel will discuss recent IRS enforcement actions for high income taxpayers, voluntary disclosure options, current challenges fac... Read More

Canadian Tax Planning for U.S.-Based Taxpayers: Key Challenges for Businesses
Canada-U.S. Tax Treaty, Tax Issues for Acquisitions or Financing Canadian Businesses, and...
October 13, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of Canadian tax considerations for U.S.-based taxpayers. The panel will discuss the Canadian tax system as applied to U.S. based taxpayers, doing business in Canada considerations, acquisitions and financing Canadian oper... Read More

Tax Traps for U.S. Partnerships With Foreign Partners: Distributions, Sale of Interests, W...
IRC 871 and 881, IRC 1446(f), FIRPTA, IRC 864(c)(8), Issues for Tiered Partnerships, and M...
October 6, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and other tax professionals an in-depth analysis of critical tax challenges for partnerships with foreign partners. The panel will discuss tax considerations when making partnership distributions to foreign partners, withholding and reporting requirements... Read More

Drafting Tax Distribution Provisions in Partnership Agreements: Protecting Against Tax on...
October 1, 2020 CLE, CPE, EA CLE On-Demand, Download
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This course will provide a focused and practical guide to tax counsel in drafting partnership tax distribution provisions. The panel will define the issue of "phantom income" and detail the negotiating process and strategies on whether to include tax distributions. The panel will also provide sample... Read More

FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, FBAR Defense Strategie...
September 24, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers a critical analysis of FBAR examination, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, IRS guidance and relief for certain taxpayers, and new cases with issues of first impression relatin... Read More

Umbrella Partnership Structures: Key Tax Considerations for Up-C and UPREITs, Compensation...
Application of Sec. 162(m), Anti-Abuse Regs, Flow-Through Treatment, Maintaining Tax Defer...
September 22, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals on the essential tax issues for umbrella partnership structures. The panel will discuss tax considerations for Up-C and UPREIT structures, the application of Sec. 162(m) to compensation paid by partnerships, key issues stemming from tax receivable and... Read More

Pre-Immigration Tax and U.S. Investment Planning for High Net Worth Individuals
Navigating the EB-5 Investor Visa Program, Leveraging Tax Credits, and Avoiding Tax Traps
September 10, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a comprehensive guide to the tax and investment planning challenges and opportunities for high net worth foreign clients seeking to immigrate to the United States. The panel will discuss strategies for minimizing the U.S. tax impact of f... Read More

Tax Issues for S Corps: Federal and State Tax Challenges, Planning Considerations for Taxp...
September 2, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals on critical tax challenges and recent developments for S corporations. The panel will discuss key tax law regulations and developments impacting S corporations, IRS guidance, the impact of the CARES Act and related PPP loan forgiveness, QBI deduction,... Read More

Tax Implications of Paycheck Protection Program and Related Expenses: Deductibility, Cance...
PPP Forgiveness and Exclusion from Taxable Income, Notice 2020-32 Disallowance of Deductio...
August 13, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide guidance to tax counsel and advisers on critical tax issues associated with Paycheck Protection Program (PPP) loans and related expenses. The panel will discuss the latest developments and IRS guidance, challenges of loan forgiveness and exclusion from taxable income... Read More

Tax Perils of Passive Foreign Investment Companies for U.S. Shareholders: Reporting Obliga...
PFIC Rules, Determining Company Status, Exceptions, Allocation of Income, Qualified Electi...
August 5, 2020 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on the tax challenges and reporting obligations of U.S. shareholders of passive foreign investment companies (PFICs) under current tax law. The panel will discuss key tax provisions impacting the reporting of income from PFICs by U.S. tax... Read More

IRS Partnership Audit Rules for Tax Counsel: Managing Partnership Operations and Governanc...
Partnership Agreement Drafting Considerations, Commercial Impacts, Transfers and Admission...
July 30, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with an up-to-date look at the drafting, commercial, and compliance implications of the partnership audit rules, including a discussion of IRS guidance on issues presented by the statute. The panel will describe the partnership audit processes in detail,... Read More

Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency...
Key Reporting and Compliance Challenges, Protective Filings, Relief Under Rev. Proc. 2020-...
July 16, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on critical tax presence and residency issues for individuals and businesses stemming from COVID-19. Read More

Section 163(j) and the CARES Act: Special Partnership Rules, International Tax and U.S. St...
June 25, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals a critical analysis of the recent changes made to Section 163(j) under the CARES Act. The panel will discuss new special partnership rules and the impact of the revisions to Section 163(j) under the CARES Act on international and U.S. state taxes. T... Read More

CARES Act, NOL Rules, IRS Guidance: Critical Tax Considerations and Mitigation Planning fo...
Impact of Pandemic on Cash and Liquidity, BEAT, GILTI, FDII, Sec. 965 Transitions Tax
June 2, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide guidance to tax counsel and advisers on critical tax considerations amid the COVID-19 pandemic. The panel will discuss tax implications and potential opportunities under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, recent IRS guidance, NOL rules, a... Read More

Partnership Non-Cash Property Distributions: Hot Assets, Disguised Sales, and Other Critic...
Structuring Partnership Distributions Without Triggering Gain Recognition Under Secs. 704(...
May 21, 2020 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals on the tax issues stemming from partnership non-cash property distributions. The panel will discuss critical issues in structuring non-cash property distributions, key exceptions, questions in applying Sections 751, 704(c), 707, 731(c), 737, and 752,... Read More

New IRS Tax Collection and Audit Guidance for Taxpayers in Response to COVID-19
Relief for Complex Collection Cases, Strategies for Individuals and Small Businesses, Secu...
May 19, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on grasping critical tax collection and audit-related issues and solutions in light of the COVID-19 pandemic. The panel will discuss essential items of the new IRS People First Initiative and subsequent guidance including, unique complian... Read More

Income Tax Treaty Practice for Tax Counsel: Planning and Structuring Transactions to Maxim...
Understanding and Applying Key Tax Treaty Provisions and the Coming Changes
May 7, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a solid overview and explanation of key tax treaty provisions that tax counsel must master in structuring cross-border transactions. The panel will focus on individual, small business, and middle-market positions and will enable tax counsel to advise... Read More

New IRS Foreign Tax Credit Regulations: Allocating Expenses, Assigning Foreign Taxes to In...
April 16, 2020 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will provide tax practitioners a critical analysis of the new IRS final and proposed regulations on foreign tax credits. The panel will discuss the impact of the final rules on tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes o... Read More

New IRS Base Erosion and Anti-Abuse Tax (BEAT) Final Regulations
Sec. 6038A Reporting Issues, Application to Partnerships, Gross Receipts and Base-Erosion...
April 1, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals and advisers with a practical guide to the recently issued IRS final regulations on the base erosion and anti-abuse tax (BEAT). The panel will discuss critical provisions of the new IRS final regulations, application to pass-through entities, determ... Read More

Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers
Self-Employment Taxes, Worker Classification, Voluntary Closing Agreements, California AB...
March 31, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on critical issues relating to employment taxes. The panel will discuss essential techniques to avoid penalties and handling IRS audits stemming from employment taxes. The panel will also discuss worker classification issues and methods t... Read More

Structuring Redemptions of Partnership and LLC Interests: Issues Unique to Liquidating Dis...
IRC 754 Elections, Section 736(b) Payments, Character and Timing of Gain, Installment Sale...
March 5, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with specific and practical guidance to navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss common pitfalls and uncertainties under current tax law and outline best practices to struct... Read More

New IRS Cryptocurrency Guidance on Hard Forks and Airdrops: Rev. Rul. 2019-24, Audit Risks...
Recent IRS Audit Initiatives, Reporting, and Compliance Issues
February 27, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide an in-depth analysis of recently released IRS Revenue Ruling 2019-24 and the updated frequently asked questions (FAQs) regarding taxation of cryptocurrency. The panel will discuss the key provisions of Rev. Rul. 2019-24, recent IRS initiatives to identify and tax vir... Read More

Partnership Representatives: IRS Regulations Under Section 6223 and Challenges for Pass-Th...
Audit Procedures; Disregarded Entities as Partnership Representatives; Termination and Rep...
February 13, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers guidance to IRS rules on the designation of partnership representatives for purposes of the centralized audit rules. The panel will discuss the regulations under Section 6223 and the impact on pass-through entities, IRS procedural and adminis... Read More

Section 199A Implementation and IRS Examination Issues: Critical QBI Issues for Individual...
February 11, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals on critical issues in the implementation of Section 199A qualified business income (QBI) deductions and essential items of focus for an IRS examination and audit. The panel will discuss what to expect when the IRS begins auditing tax returns claiming... Read More

Avoiding Disguised Sales in Qualified Opportunity Funds: Critical Tax Considerations for Q...
Recent IRS Regulations, Application of Section 707, Exceptions, Assumption of Liabilities,...
January 30, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals an in-depth analysis of qualified opportunity funds (QOFs), specifically focusing on recent IRS regulations and partnership disguised sales. The panel will discuss current IRS regulations on the application of disguised sale rules to investments in... Read More

New IRS Regulations of Cloud Transactions and Digital Content: Sourcing Rules, Lease vs. S...
January 28, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers a detailed analysis of the taxation of cloud transactions and digital content. The panel will discuss applicable IRS tax rules and recent regulations, sourcing of income rules and challenges, treatment of payment of services versus lease paym... Read More

Goodwill in Corporate Asset Sales: Tax Planning, Personal vs. Corporate Goodwill, Allocati...
January 23, 2020 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will discuss an important and revitalized area of tax law--goodwill in corporate asset sales. Our panelists will provide attendees with the techniques necessary for the appropriate and beneficial use of goodwill to provide clients with tax planning opportunities. Read More

Structuring Tax-Free M&A Deals: Navigating IRC 368 and 351, Selecting the Appropriate Stru...
January 16, 2020 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will help tax counsel prepare to navigate the complex maze of structuring tax-free mergers and acquisitions and offer insights on the pros and cons of each option. Read More

Multistate Tax Treatment of Multi-Tier Partnerships: State Tax Issues for Nonresident Tier...
Reconciling State Recognition Rules, Apportionment from Lower-Tier Pass-Through Entities,...
October 31, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, advisers, and compliance professionals with a practical guide to navigating the state tax complexities involved in multi-tiered partnerships. The panel will discuss various state rules governing apportionment of income from lower-tier pass-through entiti... Read More

Centralized Audit Regime Issues for Buyers and Sellers of Partnership Interests: Protectin...
Structuring the Purchase or Sale of Partnership Interests Under New IRS Audit Rules
October 29, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide guidance to tax counsel and advisers on BBA audit regime issues faced by buyers and sellers of partnership interests. The panel will discuss key points of interest in negotiating and structuring purchases or sales of partnership interests in light of the new partners... Read More

Partnership and LLC Excess Business Loss Limitations: Section 461(l) Challenges and Planni...
October 2, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with an in-depth analysis of the loss limitation rules of Section 461(l) for non-corporate taxpayers passed in the 2017 tax reform bill. The panelist will discuss what items are included or excluded in the business loss calculations, the effe... Read More

Tax Treatment of Cryptocurrency Losses Suffered by Individual Taxpayers
Key Tax Considerations After Crypto Exchange Shutdown, Bankruptcy, and Scams
September 12, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers on the tax treatment of cryptocurrency losses for individual taxpayers. The panel will discuss critical tax rules and considerations for investors and holders of cryptocurrency, available taxpayer options in cases of crypto exchange shutdown, b... Read More

International Tax Compliance: Navigating Tax Implications of Cross-Border Activities
Reporting and Filing Requirements, Guidelines on IRS Issue-Based Examinations, Audits and...
September 4, 2019 CLE, CPE CLE On-Demand, Download
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This course will provide tax counsel and advisers with a practical discussion of the tax implications, reporting requirements of cross-border activities, and issue-based examinations of foreign activities of individuals and companies. The panel will review complex international tax issues associated... Read More

Tax Treatment of Carried Interest: Planning Opportunities for Tax, Private Equity and Real...
IRC Section 1061, Capital Contributions, Transfers to Unrelated Parties, Special Allocatio...
August 29, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide guidance to tax counsel and advisers on the new tax law's impact on the treatment of carried interest and available planning opportunities. The panel will discuss the application of Sec. 1061, Sec. 1231 property, implications of related party transactions, and planni... Read More

Foreign Entity Selection and Taxation: Avoiding Tax and Reporting Pitfalls of Foreign Stru...
Planning for U.S. Owners of Offshore Businesses, Treatment of Foreign Trusts and Other Ent...
August 27, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of the tax and operational impacts of foreign entity selection for individuals owning controlling interests in international businesses. The panelist will discuss the tax issues that arise in foreign entity selection, wit... Read More

New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment
June 5, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, accountants and other advisers with a critical first look at new IRS initiatives on taxpayer compliance and reporting obligations for cryptocurrency transactions. The panel will discuss the IRS position on cryptocurrency as property rather than cash, ana... Read More

IRC Section 338(h)(10) Election Strategies for Tax Counsel
Leveraging the Election in Structuring Acquisitions, Dispositions, Asset and Stock Transfe...
March 27, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a review of the application, operation, and impact of the Section 338(h)(10) election. The panel will provide tax planning strategies to optimize tax benefits and minimize pitfalls in the election under the new tax law. Read More

Tax Reform for Pass-Through Entities: IRS Regulations, Planning Techniques, Loopholes, QBI...
February 21, 2019 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a review of the application and impact of the current tax law on pass-through entities. The panel will discuss new tax law changes impacting pass-through entities, recent IRS regulations, and provide tax planning strategies to optimize t... Read More

Reconciling State and Federal Audits After New IRS Partnership Audit Regulations: Tax Repo...
MTC Model Partnership Audit Reporting Statute; State Tax Audit, Assessment and Collection...
November 13, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax professionals with an up-to-date look at the impact of the new IRS partnership audit rules on state tax regulations, audits, assessments and collection procedures. The panel will discuss recently released IRS final regulations, an overview of the new partnership... Read More

Tax Issues in Transferring LLC and Partnership Interests
Navigating the Complex IRS Rules for Buying, Selling or Redeeming Partnership Interests
November 6, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions. Read More

New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment
October 18, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel, accountants and other advisers with a critical first look at new IRS initiatives on taxpayer compliance and reporting obligations for crypto currency (e.g. Bitcoin, Coinbase) transactions. The panel will discuss the IRS position on crypto currency as pro... Read More

Tax Reform for Pass-Through Entities: Impact of New Tax Law on Partnerships, LLCs and S-Co...
Planning Techniques, Loopholes, Qualified Business Income Deductions and Limitations
October 4, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a review of the application and impact of the new tax bill on pass-through entities. The panel will discuss new tax law changes impacting pass-through entities and provide tax planning strategies to optimize tax benefits and avoid pitfal... Read More

Avoiding Tax Pitfalls of New EU Directive Targeting Cross-Border Tax Planning Mechanisms
Mandatory Disclosures by Intermediaries, Reporting Requirements, Planning Techniques and M...
September 13, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on recent directives of the European Union (EU) regarding mandatory reporting obligations for intermediaries and taxpayers. The panel will discuss the implications of the EU directive on U.S. companies, required disclosures of tax arrange... Read More

Contribution Default Remedies for LLCs and Partnerships: Tax Consequences of Dilution, Set...
September 6, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on structuring contribution-default remedies for LLCs and partnerships. The panel will discuss the complexities of contribution-default remedies, such as interest dilution, set-offs and loans. The panel will also tackle a variety of tax i... Read More

South Dakota v. Wayfair: Overturning Physical Presence Rule, New Tax Challenges for Multis...
Sales Taxation Post-Wayfair for Remote Sellers of Goods and Services; Key Tax Planning Con...
August 23, 2018 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will guide tax professionals and advisers on the state tax issues facing remote sellers of taxable goods and services after the U.S. Supreme Court's decision in South Dakota v. Wayfair. The panel features attorneys who represented Wayfair in the case who will discuss the ramifica... Read More

Recourse and Nonrecourse Liability in Partnership Agreements
Leveraging Section 752 to Minimize Tax Impact of Partnership Liability and Debt Allocation...
May 10, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will guide tax counsel and advisers on navigating the complexities of characterizing partnership liabilities as recourse or nonrecourse. The panel will explain the significant tax and economic consequences for partners caused by distinctive treatments under the current tax code a... Read More

Hedge Funds and IRS Partnership Audit Rules
Advanced Tax Strategies in Structuring Private Investment Funds in Light of New IRS Rules
April 26, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with guidance on the impact of the IRS partnership audit rules on the structure and operations of hedge funds and private investment funds. The panel will discuss structuring considerations for new funds in light of the new regulations, and will detail ne... Read More

Structuring Leveraged Buyouts: Advanced Planning and Tax Considerations for Debt Financed...
February 7, 2018 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will offer tax and corporate professionals practical guidance on structuring leveraged buyouts and tax-efficient strategies for debt acquisition financing. The panel will discuss the use of debt finance in structuring asset and stock purchase transactions and mergers, and detail... Read More

Series LLCs: Advanced Planning and Tax Implications
Advantages and Disadvantages, Existing IRS Guidance, Tax Pitfalls, and Alternative Structu...
February 1, 2018 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide counsel and tax professionals an instructive review of recent trends in using series LLCs. The panel will compare the advantages and disadvantages, discuss federal tax implications of tax reform, analyze existing IRS guidance and examine tax pitfalls and alternatives... Read More

Tax Reform and Accelerating Deductions: Payroll Tax Accruals and Permanent Tax Savings
Payroll Tax Liability and Deductions, and Impact on Current and Deferred Compensation
January 25, 2018 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will offer tax counsel insight and guidance on significant tax advantages in the impending tax reform, which will include corporate income tax reductions related to the deduction of payroll tax expense. The panel will discuss the effects of changes in the corporate income tax rat... Read More

Inadequate Tax Basis: Leveraging Basis Rules for S Corporations
Analyzing Guaranteed Loans, Incorporated Pocketbook Theory, and Back-to-Back Loans
January 4, 2018 CLE, CPE, EA CLE On-Demand, Download
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This course will provide tax counsel and advisers with techniques to overcome challenges associated with inadequate basis in S corporations. The panel will discuss IRS regulations that provide resolution to some of the most confusing areas of inadequate basis. Read More

Minimizing IRS Scrutiny of Private Equity Management Fee Waivers: Structuring Defensible W...
December 12, 2017 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will explore designs for private equity management fee waivers in light of the latest developments in the law, industry practice and potential tax reform legislation. The panel will discuss critical terms for agreements to minimize the risk of IRS challenge to new arrangements an... Read More

The "Fractions Rule" in Partnership Agreements: Drafting Section 514(c)(9)(E) Compliant Al...
Avoiding UBTI Triggers Through Savings Clauses and Other Structuring Tools
November 28, 2017 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and partnership advisers with a practical, comprehensive guide to the "fractions rule," governing allocations between tax-exempt partners and taxable partners. The panel will define the specific issues and challenges that the fractions rule presents in st... Read More

New IRC 721(c) Regulations and Contributions to Foreign Partnerships
Remedial Allocations and Structuring Transfers to Foreign Partnerships to Ensure Gain Defe...
September 6, 2017 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel with a detailed and practical guide to the rules governing contributions by U.S. persons to "related foreign partnerships," particularly in the wake of new IRC 721(c) Treasury Regulations, which effectively end non-recognition treatment of partnership con... Read More

Revenue Ruling 2017-09: New IRC 355 North-South Spinoff Transaction Guidance and Resumptio...
August 17, 2017 CLE, CPE, EA CLE On-Demand, Download
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This course will provide tax counsel with a critical look at recent IRS guidance on "north-south" transactions in connection with tax-free spin-offs, issued in Rev. Rul. 2017-09. The panel will discuss the facts presented in the ruling under which the IRS will respect the separate steps of a north-s... Read More

Advanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act In...
July 26, 2017 CLE, CPE, EA CLE On-Demand, Download
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This course will provide tax counsel and advisers with a thorough and practical guide to strategies for administrative challenges and defenses against penalty assessments for FBAR violations. The panel will contrast the penalty structures between FBAR and other foreign-related information filings an... Read More

Tax Challenges for Counsel to Nonprofit Joint Ventures and Alliances
Evaluating Tax Consequences of Entity Structure and Activities, Maintaining Tax-Exempt Sta...
May 25, 2017 CLE, CPE CLE On-Demand, Download
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This CLE/CPE course will prepare tax counsel to nonprofits to properly establish joint ventures or other business alliances, including structuring the business entity, defining the scope of activities and intended operations, maintaining tax-exempt status, and addressing UBIT and Form 990 disclosure... Read More

Sales Transactions of Controlled Foreign Corporation Stock: Avoiding Tax Impact For Buyers...
Navigating Sections 338(g) Elections and 901(m) Limitations for Buyers and Section 1248 Re...
March 22, 2017 CLE, CPE, EA CLE On-Demand, Download
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This CLE course will provide tax counsel with a practical guide to navigating the IRS rules governing sales transactions involving controlled foreign corporation (CFC) stock. The panel will discuss the IRC 901(m), limitations on foreign tax credit benefits of a Section 338(g) election for buyers of... Read More

IRS Enforced Collection Actions: Challenges and Responses to Federal Tax Liens and Levies
Mitigating the Effects of Tax Liens, Navigating the Levy and Asset Seizure Process
February 14, 2017 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax attorneys, CPAs and enrolled agents with a comprehensive and practical guide to navigating the process of responding to and challenging IRS collection actions, both Notice of Intent to Levy and Notice of Federal Tax Lien. The panel will discuss the lien process,... Read More

IRC 704(c) for Tax Counsel: Structuring Partnership Agreements for Contributions of Built-...
Avoiding 704(c) and 737 Gain or Loss Shifting Pitfalls, Navigating Complex Basis Adjustmen...
January 24, 2017 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a comprehensive and practical guide to navigating the complex requirements of IRC Section 704(c) in structuring partnership agreements. The panel will offer practical drafting tools, including sample language, for ensuring that partnersh... Read More

Structuring Section 708 Partnership Mergers Absent IRS Guidance: Avoiding Termination in C...
Assets-Over vs. Assets-Up Transactions, Maintaining Continuity of Interest, and Deferring...
September 28, 2016 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a practical guide to structuring partnership transactions to qualify for partnership merger treatment as a continuing interest under Section 708. The panel will identify tax issues of collapsing separate upper-tier partnerships (UTPs) an... Read More

Tax Counsel's Guide to Partnership Disguised Sales Rules: Structuring Transactions to Avoi...
Navigating Section 707 to Uphold Classification of Partners' Contributions and Distributio...
August 17, 2016 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a thorough, practical guide to the disguised sale rules for partnerships since the Fourth Circuit's decision in Route 231 LLC v. Commissioner. The panel will discuss the facts and circumstances tests listed in the Treasury Regulations, d... Read More

The Panama Papers: Guidance for Tax Counsel to Mitigate Client Tax Penalties and Criminal...
Conducting Account Reviews to Identify Legal Exposures, Designing Disclosure Strategy, Lev...
July 26, 2016 CLE, CPE, EA CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with guidance for clients with offshore holdings who may fall under the scope of the "Panama Papers" or similar disclosure of shelter holdings. The panel will discuss due diligence requirements and processes, disclosure strategies, Offshore V... Read More