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Structuring Tiered Partnerships: Advanced Tax Planning Strategies, Avoiding Tax Traps
Treatment of Allocations and Deductions, Application of Sec. 704 and 743
September 21, 2018 CLE, CPE Live Webinar

This CLE/CPE webinar 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 new IRS partnership audit rule... 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 Webinar

This CLE/CPE webinar 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 pitfa... Read More

Section 199A: New IRS Regulations, Deductions, Limitations, Complexities and Opportunities...
Determining Qualified Business Income, Loss Carryover, Reformation Considerations and More
October 11, 2018 CLE, CPE, EA Live Webinar

This CLE/CPE webinar will provide tax professionals and advisers with an in-depth understanding of Sec. 199A, recent IRS regulations and how to claim the qualified business income deduction. The panel will discuss the strict rules, requirements and limitations of Sec. 199A and the available planning... 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...
October 16, 2018 CLE, CPE, EA Webinar

This CLE/CPE webinar 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

New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment
October 18, 2018 CLE, CPE, EA Webinar

This CLE/CPE webinar 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 pr... 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

This CLE/CPE webinar 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 arrang... Read More

New Section 951A: GILTI Rules for Individual and Non-C Corporation CFC Shareholders
Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GI...
September 12, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals with guidance on the challenges of the global intangible low taxed income (GILTI) provisions under the new tax bill. The panel will discuss treatment of controlled foreign corporation (CFC) income, reporting requirements for individual and non-C co... Read More

Contribution Default Remedies for LLCs and Partnerships: Tax Consequences of Dilution, Set...
September 6, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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... 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

This CLE/CPE webinar 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 ramific... Read More

New IRS Partnership Audit Rules for Tax Counsel: Massive Changes to Partnership Operations...
Partnership Agreement Drafting Considerations, Commercial Impacts, Transfers and Admission...
August 16, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE video webcast will provide tax counsel with an up-to-date look at the drafting, commercial and compliance implications of the new partnership audit rules, including a discussion of recent IRS guidance on issues presented by the statute. The panel will describe the new partnership audit... Read More

Nonresident Alien Tax Compliance: Challenges and Planning Techniques for Tax Professionals
Recent IRS Compliance Campaign, ECI vs. FDAP Income, Reporting Requirements, Exemptions, D...
August 7, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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

IC-DISC and FDII: U.S. Export Incentives Post-Tax Reform, Pricing Commissions and Structur...
Maximizing Tax Savings, Pass-Through Entities vs. C-Corporations, Distributor Companies an...
July 31, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with an advanced guide to structuring Interest Charge-Domestic International Sales Corporation (IC-DISC) companies. The panel will go beyond the basics to address alternative and sophisticated structures (including agricultural co-ops), comm... 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...
July 24, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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

Tax Issues in Sale of Partnership and LLC Interests: Structuring the Purchase Agreement
Best Practices for Drafting and Negotiating Tax Provisions
July 19, 2018 CLE, CPE CLE On-Demand, Download

The CLE/CPE webinar will review the tax issues involved with structuring purchase agreements for partnership or LLC interest. The panel will address allocation of income gains and losses, allocation of purchase price, payment terms in the purchase agreement, the impact of new tax law and discuss tax... Read More

New Section 951A: GILTI Rules for Individual and Non-C Corporation CFC Shareholders
Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GI...
July 12, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals with guidance on the challenges of the global intangible low taxed income (GILTI) provisions under the new tax bill. The panel will discuss treatment of controlled foreign corporation (CFC) income, reporting requirements for individual and non-C co... Read More

Navigating Multistate Tax Issues With Pass-Through Entities
Reconciling State Recognition Rules and Overcoming Complexities With the Taxation of S Cor...
June 14, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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

Voluntary Disclosure of Foreign Assets: Current Challenges for Noncompliant U.S. Taxpayers
IRS Ends the OVDP; Other Options for Compliance, Avoiding Penalties and Potential Criminal...
May 31, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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, implications of the IRS' termination of the Offshore Voluntary Disclosure... Read More

IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Tax Savings Po...
Navigating Applicable IRC Sections, Formation and Qualification Issues
May 24, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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

Qualified Opportunity Zones and Tax Credits: Capital Gain Deferral Mechanisms Under New Se...
IRC 45D(e) Requirements, Step-Up in Basis, Appreciation Exclusion, Tax Planning Strategies...
May 17, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide tax counsel and advisers with a detailed analysis of the qualified opportunity zones tax-incentive mechanism provided under the tax reform law. The panel will discuss the necessary legal requirements and processes to obtain the tax credit, describe methods to ensure def... 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

This CLE/CPE webinar 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... Read More

New Tax Considerations for M&A Transactions: NOL Limitations, Deemed Income, Withholding T...
May 3, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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

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

This CLE/CPE webinar 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 n... Read More

Structuring Waterfall Provisions in LLC and Partnership Agreements
Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences
April 12, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 in the provisions, such as approaches to drafting priority returns... Read More

IRC § 338(h)(10) Election Strategies for Tax Counsel: Opportunities and Risks Under Tax Re...
Leveraging the Election in Structuring Acquisitions, Dispositions, and Asset and Stock Tra...
March 29, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a review of the application, operation and impact of the Section 338(h)(10) election in acquisitions. The panel will provide tax planning strategies to optimize tax benefits and minimize pitfalls in the election under the new tax reform law. Read More

New Section 199A: Deductions, Limitations, Complexities and Opportunities for Pass-Through...
Determining Qualified Business Income, Loss Carryover, Reformation Considerations and More
March 22, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals and advisers with an in-depth understanding of Sec. 199A and how to claim the qualified business income deduction. The panel will discuss the strict rules, requirements and limitations of Sec. 199A and the available planning techniques to maximize... Read More

Pre-Immigration Tax and U.S. Investment Planning for High Net Worth Individuals
Navigating the EB-5 Investor's Visa Program, Leveraging Tax Credits and Avoiding Tax Traps
March 8, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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... Read More

International Tax Compliance: Navigating Implications of Cross-Border Activities
Tax Reform Implications, Latest LB&I Initiatives, Reporting and Filing Requirements, Guide...
March 1, 2018 CLE, CPE CLE On-Demand, Download

This webinar will provide tax counsel and advisers with a practical discussion of the IRS Large Business and International (LB&I) division's identification and selection of additional compliance campaigns to further efforts toward issue-based examinations of foreign activities of individuals and com... 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
February 21, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 pitfa... Read More

Structuring Leveraged Buyouts: Advanced Planning and Tax Considerations for Debt Financed...
February 7, 2018 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar 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

This CLE/CPE webinar 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 alternative... 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

This CLE/CPE webinar 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 ra... Read More

Structuring Tax-Free M&A Deals: Navigating IRC 368 and 351, Selecting the Appropriate Stru...
January 11, 2018 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar 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

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

This webinar 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

Structuring Foreign UBTI Blocker Corporations for Exempt Orgs: Offshore Blockers to Hold A...
Nonprofit Entities Owning Private Equity, Hedge Funds and Offshore Funds
December 19, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a practical guide to structuring foreign blocker corporations for U.S. tax exempt organizations. The panel will outline the benefits and potential risks to tax exempt organizations (TEOs) of investing in foreign "blocker" corporations to block UBTI.... Read More

Minimizing IRS Scrutiny of Private Equity Management Fee Waivers: Structuring Defensible W...
December 12, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 a... 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...
December 5, 2017 CLE, CPE, EA CLE On-Demand, Download

This 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, outlining tax timing and treat... 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

This CLE/CPE webinar 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 s... Read More

Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and A...
November 1, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 major foreign information reporting forms and their assoc... Read More

Form 5471 Substantial Compliance Rules: New IRS International Practice Unit Guidance
When Will the IRS Deem An International Tax Information Filing as Not "Substantially Compl...
October 24, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide tax counsel and advisers with a practical discussion of recent 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 d... Read More

IRC 751 "Hot Asset" Treatment: New Rules for Calculating Ordinary Income Recharacterizatio...
New IRS Proposal on Determining Partners' Share of Section 751 Ownership
October 17, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a practical and thorough guide to structuring partnership distributions of Section 751 "hot assets," such as inventory and unrealized receivables. The panel will discuss the default "distribution as exchange" rule and offer details on the substantiv... Read More

Gain on Sales of U.S. Partnership Interests by Foreign Partners After Grecian Magnesite v....
Entity vs. Aggregate Approach to Determine if Gain is Effectively Connected U.S. Income
October 3, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide tax counsel and advisers with a critical first look at the landmark Tax Court holding in Grecian Magnesite Mining v. Commissioner that certain gain realized by a foreign partner on the disposition of a U.S. partnership interest was neither U.S.-sourced nor effectively c... 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
September 26, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to utilizing a Section 336(e) step-up election in the acquisition of a target corporation. The panel will contrast the 336(e) election with 338(h)(10) treatment, outline the requirements for qualification, and detail t... 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
September 12, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a detailed discussion of best practices for requesting abatements of IRS penalties due to failure to properly file required international information forms such as the FBAR, Form 8938, and Forms 5471 and 5472. The panel will discuss the current tren... 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

This CLE/CPE webinar 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 co... Read More

Partnership Exchanges: Structuring "Drop and Swap" and "Mixing Bowl" Transactions
Minimizing the Risk of an Unfavorable Audit Outcome
August 30, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax advisers with knowledge and tools to advise partnership clients looking to convert to a tenancy-in-common form of ownership of real estate. Tax advisers may recommend such a conversion in contemplation of a future sale of property or to create a master limited l... 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

This webinar 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-... Read More

Removing PFIC Taint on Foreign Investments Through Subsequent Year QEF Elections
Navigating PFIC Rules of IRC Sections 1291-1298
August 1, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide tax attorneys and counsel with a practical guide to removing the "taint" of foreign investments that are treated as passive foreign investment companies (PFICs). The panel will discuss the complex qualified electing fund (QEF) election rules, detailing the advantages, disad... Read More

Advanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act In...
July 26, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar 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 a... Read More

IRC 831(b) Small Captives After the PATH Act: Meeting New Diversification Requirements and...
July 19, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with practical tools and guidance to ensure that clients utilizing small captive insurance companies are fully compliant with the Section 831(b) rules. The panelist will discuss the PATH Act's changes in both tax benefits and compliance burd... Read More

Structuring Foreign Investment in U.S. Real Estate: Entity Selection and Transaction Struc...
Navigating FIRPTA, Determining Individual vs. Entity Ownership Structures, Achieving Optim...
July 12, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. real estate, outline best practices for determining the purchasing entity, and review tax planning opportunities in structuring the deal. Read More

Asset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting and Structuring Technique...
June 27, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide practical guidance into the best practices for tax counsel advising clients buying or selling a business on 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 must... Read More

FBAR and U.S. Tax Reporting and Compliance Requirements for Foreign Assets
Unraveling Foreign Asset and Income Reporting Obligations, Evaluating and Navigating the O...
June 20, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide counsel and tax advisers with the tools necessary to navigate the new rules regarding FBAR and offshore voluntary disclosure programs (OVDPs) and assist clients with developing programs that provide workable solutions. Read More

Structuring Redemptions of Partnership and LLC Interests: Navigating Issues Unique to Liqu...
IRC 754 Elections, Section 736(b) Payments, Character and Timing of Gain, Installment Sale...
June 14, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 in the tax code and outline best practices to structure t... 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...
June 7, 2017 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes. 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
May 31, 2017 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar 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 i... 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

This CLE/CPE webinar 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 disclosur... Read More

Structuring Targeted Partnership Tax Allocations: Complying With IRC 704(b)
Determining Substantial Economic Effect, Distinguishing Targeted and Regulatory Allocation...
May 3, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisors with the guidance necessary to correctly implement targeted partnership tax allocations. The panel will explain the complex requirements of IRC Sec. 704(b) and provide best practices for maximizing the tax benefits of targeting partnership a... 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
April 26, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a solid overview and explanation of key tax treaty provisions that tax counsel must master in structuring cross-border ownership structures and transactions. The panel will focus on individual, small business, and middle-market positions and will en... Read More

Form 3520 Foreign Trust Reporting for Tax Counsel: Navigating Filing Requirements and Pena...
Establishing Reasonable Cause Exceptions, Appeals Prior to Payment, Collection Due Process...
April 6, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a comprehensive and practical guide to a deep exploration into 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. Th... 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

This CLE webinar 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

Tax Issues in Transferring LLC and Partnership Interests
Navigating the Complex IRS Rules for Buying, Selling or Redeeming Partnership Interests
March 2, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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

IRC 732(d) Partnership and LLC Basis Adjustments for Tax Counsel
Mastering Elective and Mandatory Basis Adjustments on Distributed Property Absent a Partne...
February 23, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 surroundin... 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

This CLE/CPE webinar 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

New IRS Partnership Audit Rules for Tax Counsel: Preparing for Massive Changes
Partnership Agreement Drafting Considerations, Commercial Impacts, Transfers and Admission...
February 8, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with an up-to-date look at the drafting, commercial and compliance implications of the new rules, including a discussion of potential IRS guidance on issues presented by the statute. The panel will describe the new partnership audit processes in detail,... 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

This CLE/CPE webinar 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 partners... Read More

Partnership Allocations of Rehabilitation, New Market and Other Tax Credits: Navigating Co...
January 5, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 will go into detail on provisions for... Read More

Structuring Contributions of Appreciated Property to Partnerships: Avoiding Tax Recognitio...
Navigating Allocation Challenges, the "Seven Year Rule" of Section 737, and New Debt Class...
December 20, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a comprehensive guide to the tax consequences of contributing appreciated property to a partnership or multi-member LLC. The event will present a framework of the specific tax treatment of the contribution of appreciated property with debt, allocati... Read More

Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and A...
November 22, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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, starting with an understanding of the major foreign information reporting forms, and the associated... 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

This CLE/CPE webinar 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) a... 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

This CLE/CPE webinar 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,... 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

This CLE/CPE webinar 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... Read More

Structuring U.S. Trusts Classified as Foreign Trusts for Income Tax Purposes
Leveraging FATCA Rules in International Tax Planning, Ensuring Correct Form 8938 Reporting
July 6, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 co... Read More

Navigating New Section 385 Regulations on Related-Party Debt: Sweeping Changes on the Hori...
Avoiding Reclassification of Debt to Equity, Structuring Inter-Company Debt Instruments to...
June 7, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide a critical first look into the IRS proposed regulations under Section 385 to reclassify certain related-party debt as equity for U.S. tax purposes. The panel will discuss the scope of the proposed regulations, examine what types of structures and transactions are su... 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
May 31, 2016 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar 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

Tax Strategies for Limited Partner Investors in Private Investment Funds
Avoiding Tax Traps Through Side Letters and Other "Hidden" Agreements
April 13, 2016 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with a detailed guide to the tax issues of various types of private investments funds, including private equity, venture capital, and real estate funds. The panel will discuss the tax implications of various fund structures, identify potenti... Read More

IRC Section 355 Corporate Spin-Off Transactions: Optimizing Tax Treatment in Divestitures
March 30, 2016 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide tax counsel with a practical guide to the key tax considerations in structuring corporate spin-offs and carve-outs. The panel will examine key legal, business and tax considerations for deal structuring, economic terms, due diligence, asset transfers, and more. Read More

New IRS Partnership Audit Rules for Tax Counsel: Preparing for Massive Changes Ahead
Partnership Agreement Drafting Considerations, Commercial Impacts, Transfers and Admission...
March 9, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a critical first look at the drafting, commercial and compliance implications of the new IRS regulations and procedures for auditing partnerships. The panel will describe the new partnership audit processes in detail, outlining the changes that will... Read More

Foreign Financial Institution Reporting: Are You Ready for the 2016 FATCA Deadlines?
FFI Reporting Under Model II IGAs, Completing Due Diligence, Filing Form 8957 and More
February 3, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 Issues in Transferring LLC and Partnership Interests
Navigating the Complex IRS Rules for Buying, Selling or Redeeming Partnership Interests
December 15, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar 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 Partnership Transfer Rules for Contributions of Appreciated Property to Partnershi...
Understanding Impact of IRS Notice 2015-54 and Preserving Nonrecognition Treatment
October 20, 2015 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with an exploration into the ramifications of IRS Notice 2015-54, released Aug. 6, 2015, which will generally make a taxable event of any contribution of appreciated property by a U.S. person to a related partnership, unless strict requirements are satis... Read More

Tax Challenges With Private Equity Management Fee Waivers Given Newly Heightened IRS Scrut...
Structuring Waiver Arrangements in Light of the Proposed Regulations and Possible Changes...
October 13, 2015 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a review of private equity management fee waivers in light of the recently issued proposed regulations, the issues practitioners should consider when advising on fee waivers, the tax risks involved, and best practices for structuring waivers that ma... Read More

Drafting Tax Distribution Provisions in Partnership Agreements: Protecting Against Tax on...
September 24, 2015 CLE, CPE, EA CLE On-Demand, Download

This webinar 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 samp... Read More

Drafting Tax-Effective Succession Plans for Closely-Held Businesses: Navigating Competing...
Ensuring Business Continuity, Preserving Owner Liquidity, and Minimizing Tax Liabilities
September 8, 2015 CLE, CPE, EA CLE On-Demand, Download

This CPE/CLE webinar will provide tax, estate planning and business counsel with a deep exploration into best practices for drafting tax-efficient succession plans for owners of closely-held businesses, focusing on the specific tax aspects of various succession plans and helping counsel identify the... Read More

Tax Implications of Choice of Entity for Startups: An Advanced Examination for Tax Counsel
Preserving Options for Future Issuance of Stock, Venture Capital Funding, Spin Offs, Liqui...
August 27, 2015 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide a deep dive into choice of entity considerations for tax counsel, taking a life cycle planning approach to structuring the company and drafting setup documents and tax provisions to enable the company to evolve in the way the owner/founder intends. Read More

Small Business Trusts: Drafting Tax-Advantaged QSSTs and ESBTs, Reconciling Trust and S-Co...
July 7, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and family office advisers with the understanding and tools to implement best practices in drafting trust documents in anticipation of trust ownership of closely-held businesses, as well as integrating the operating documents of those businesses to prese... Read More

Streamlined Offshore Voluntary Disclosure Program: Avoiding Aggressive Enforcement Regime...
Leveraging the New OVDP Process for Claiming Non-Willful Failure to File
June 2, 2015 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide counsel and tax advisors with the tools necessary to navigate the IRS rules governing the extended 2014 Offshore Voluntary Disclosure Program (2014 "OVDP") to determine whether clients are eligible for the less arduous and punitive streamlined programs. Read More

Structuring 1031 Like-Kind Exchanges After IRS Victory in North Central Leasing
Preserving Tax-Deferral Treatment for Transactions Involving Related Parties and Qualified...
May 19, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel, advisors and real estate counsel with 2015 developments concerning IRC Section 1031, examine the requirements for like-kind property exchanges to receive tax deferrals, and provide best practices in structuring transactions to avoid adverse tax conseque... Read More

IRS CCA 201501013: Navigating New & Heightened Scrutiny of Foreign Investment Fund Lending...
March 17, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisors with the guidance necessary to survive IRS scrutiny in the context of foreign investment fund lending. The panel will cover in detail the application of the trade or business designation to foreign investment fund lending as well as effectiv... Read More

Leveraging Outbound Transfers of Corporate Stock and Other Property
Navigating Sect. 367 Gain Recognition Agreements and Sect. 6038B Regs in Cross-Border Tran...
March 4, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide guidance to counsel on the use of outbound transfers and the recently issued IRS rules impacting those transfers. The panel will discuss gain recognition agreement requirements and the reporting rules and offer best practices for leveraging outbound transfers. Read More

Attorney-Client Privilege and Work Product in Tax Controversies: New Standards for Waivers
Leveraging Defenses, Alternative Methods for Document Production, and Best Practices for I...
January 20, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide tax lawyers and advisors with the tools necessary to protect taxpayers' privileges during controversies and IRS examinations. Our distinguished panelists will review the newest legal developments and offer best practices on techniques to implement that will avoid waiver... Read More

FATCA Duties for Withholding Agents: Navigating Complex Regulations and New IRS Guidance
Determining Withholdable Payments and Payees; Applying Grandfather Rules; Collecting Docum...
December 17, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will prepare tax advisors and counsel to understand and guide withholding agents in complying with FATCA and applying the latest IRS guidance. The panel will explain complex, intricate requirements including identifying withholdable payments and payees, meeting documentation require... Read More

Exempt Organizations and S Corp Stock: Resolving Complex Tax Challenges
Leveraging Entity Structure, Navigating the IRS Supporting Organization and Excess Busines...
November 19, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will educate tax counsel and advisors on resolving the complex tax burdens with the ownership of S corporation stock by exempt organizations. Our distinguished panelists will discuss issues such as choice of entity, supporting organizations, excess business holdings tax and alte... Read More

Consolidated Group Tax Allocations: Navigating Consolidated Return Rules
Leveraging Allocation Agreements in Acquisitions, Spin-Offs, Issuances of Stock; Implement...
November 12, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax counsel and advisors with the tools necessary to advise business clients that utilize consolidated tax returns. Panelists will review the applicable rules, relevance of consolidated tax allocation agreements in various business situations and address special concern... Read More

CLO Investments: Navigating Tax Challenges in a Resurging Market
Balancing Between Debt and Equity Tranches; Applying FATCA, PFIC, CFC and NII Regulations;...
November 5, 2014 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisors with legal strategies to handle tax issues involved in collateralized loan obligations (CLOs). The panel will offer their insights and perspectives on the differences between debt and equity tranches, application of new FATCA and PFIC regula... Read More

Tax Challenges With Related Party Sales: Navigating Complex IRS Rules for Closely Held Bus...
Defining Related Parties and Applying Rules for Capital Gain Treatment, Installment Report...
October 23, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisors with the tools necessary to manage tax challenges and maximize tax savings associated with related-party transactions. The panel will review techniques in navigating the complex maze of IRS regulations applicable to the definition of related... Read More

Inversion Transactions: Structuring Deals to Capture Tax Benefits and Manage Post-Merger I...
October 1, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax advisors and counsel to small and large companies with the tools to structure deals in inversion transactions that capture the tax benefits and manage post-merger integration. Read More

Taxation of Debt Instruments: OID and AHYDO Rules, Distressed Debt, Contingent Capital
Navigating Latest IRS Rules and Overcoming Complexities in Structuring Capital Arrangement...
July 29, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will prepare tax counsel to structure complicated debt arrangements. Our experienced panel will provide best practices in handling original issue discount​ (OID), distressed debt and contingent capital. Read More

2014 FATCA Regulatory Updates: Navigating the Intricacies of Latest IRS Guidance
Implementing Treasury and IRS Amendments for NFFEs; Determining FFIs and Payee Status; Com...
June 26, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide counsel with guidance necessary to navigate the intricacies of the latest IRS guidance on FATCA compliance. The panel will review new Treasury and IRS amendments for NFFEs, FFI and payee status definitions, intergovernmental agreements (IGAs), and withholding and report... Read More

Tax Challenges for Foreign Investors in U.S. Real Estate
Navigating the Legal Considerations of Acquiring, Owning and Disposing of U.S. Real Estate
May 29, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide real estate attorneys, tax counsel and advisors with a review of tax considerations for foreign investors in U.S. real estate. The panel will address challenges for foreign investors, including form of ownership and IRS reporting obligations. Read More

Advanced Tax Strategies in Structuring Private Investment Funds
Balancing the Competing Interests of Fund Investors When Structuring Investment Funds
May 1, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax counsel and advisors with advanced guidance on how to structure private equity and other types of investment funds. The panel will review critical factors, such as type of investor, type of fund and location of fund, and address fund manager and fund investor issues... Read More

Sweeping Section 752 Rule Changes for Recourse and Nonrecourse Partnership Liability Alloc...
Incorporating New Net Value, Bottom-Dollar, Transition Rules and More
April 2, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax counsel with techniques to determine allocation of recourse and nonrecourse liabilities in light of new, coming IRS regulations. The panel will review the impact of the revisions for structuring partnership transactions and agreements, including new net value, botto... Read More

3.8% Net Investment Income Tax Final IRS Regs: Maximizing Planning Opportunities
Leveraging New Rules for Regrouping, Real Estate Safe Harbor, Sale of Closely Held Busines...
February 25, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax counsel with a road map to navigate long-awaited final regulations intended to clarify the Net Investment Income (NII) tax. The experienced panelists will discuss planning opportunities to leverage new rules for regrouping, real estate safe harbor and the new propos... Read More

Derivative Tax Challenges: Navigating the Changing IRS Rules on the Treatment of Swaps and...
January 22, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will prepare tax counsel to address current tax issues specific to derivative financial products. Our distinguished panel will help tax counsel to identify the issues and explain how to resolve them. Read More

Tax Challenges for NPO Counsel: Excess Benefit Transactions for Executive Comp and Other F...
Identifying Prohibited Transactions and Disqualified Persons, Reporting Improper Benefits,...
January 7, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will prepare non-profit tax counsel with strategies to avoid revocation of tax exempt status and liability for excise taxes based on excess benefit transactions. The panel will review different types of excess benefit transactions, identify potential disqualified persons, tax penalt... Read More

Tax Implications of Transactions Between Partners: IRC 704(c)(1)(B), 707, 737, and 751(b)
Navigating the Complex Disguised Sales Rules
December 12, 2013 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax counsel with clarification of gain/loss recognition rules of IRC Sect. 704(c)(1)(B) and Sect. 737 for partnerships. Our panel will discuss the general rules of applicability and exceptions, review characterization rules, and offer best practices for dealing with oth... Read More

Hedge Funds: Tax Advantages and Liabilities for Investors and Fund Managers
Leveraging Qualified Dividend Income, Net Investment Tax, Management Fee Waivers, and More
December 5, 2013 CLE, CPE CLE On-Demand, Download

This CLE webinar will educate tax counsel on tax issues specific to hedge funds for taxpayers and managers. Our panel will discuss tax treatment of qualified dividend income, management fee waivers and deferral, as well as tax liabilities including the new Net Investment Income Tax. Read More

Final FATCA Deadline Looms: Preparing for Compliance and Implementation
Navigating Complex IRS Regulations for Reporting Foreign Assets and Making Foreign Payment...
October 29, 2013 CLE, CPE CLE On-Demand, Download

This webinar will discuss the information reporting and withholding requirements under the recently issued Foreign Account Tax Compliance Act (FATCA) regulations. The program will focus on the latest developments in two key areas: the obligation of U.S. taxpayers to report foreign accounts, and the... Read More

New IRS "No Private Letter Ruling" Policy: Sec. 355 Transactions and a Shrinking PLR Safet...
Avoiding Unanticipated Tax Liabilities in Spin-Offs and Split-Offs Amid Increased Ambiguit...
October 23, 2013 CLE, CPE CLE On-Demand, Download

This webinar will provide guidance to tax attorneys in navigating the requirements of IRC Section 355 in spin-offs, split-offs, and other tax-free corporate separations in light of the newly effective no private letter ruling environment imposed by the IRS. Read More

Tiered Partnerships: Resolving Tax Law Complexities
Navigating Section 704(b) and (c) Allocations, Disposition of 704 (c) Property and Basis A...
October 17, 2013 CLE, CPE CLE On-Demand, Download

This CLE webinar will discuss unique allocation issues for tiered partnerships under 704(b) and (c), address application of the allocation rules to mergers and dispositions of 704(c) property, as well as basis adjustments. Read More

Structuring Tax Provisions in M&A Agreements and Protecting Section 382 Tax Attributes
August 22, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will discuss best practices for structuring and negotiating M&A agreement provisions with tax ramifications and tax-specific agreements, and will discuss the use of tax receivables agreements and ways to protect valuable Section 382 tax attributes. Read More

Partnership Tax Basis and Distribution Challenges for Counsel and Advisors
Navigating Complex Distribution Rules and Impact of Sections 731-737, 751(b) and 755
August 14, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax practitioners with an in-depth review of the rules for partnership basis adjustments and distributions under Code sections 731 through 737, 751(b) and 755. The panel will also outline how to avoid taxable pitfalls in applying the rules to partnership transactions... Read More

New 3.8% Net Investment Income Tax: Planning for Closely Held Companies
Navigating New Medicare Tax, Self-Employment Tax, and Capital Gains Issues for Members and...
July 16, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will discuss the application of these new taxes, the definition and calculation of the tax on net investment income, tax planning strategies for owners and members of pass-through entities, and avoidance of unique tax traps. Read More

Government Scrutiny of Misclassified Independent Contractors
Correcting Worker Classification, Analyzing Payroll Tax Impact, and Avoiding Benefits Pitf...
June 6, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will discuss IRS and DOL enforcement efforts regarding misclassification of independent contractors, minimizing tax liability and penalties by correcting misclassification, participating in the IRS's Voluntary Classification Settlement Program (VCSP), and ERISA/benefit plan impli... Read More

Tax Considerations in Structuring Private Equity Funds
Balancing the Competing Interests of Fund Investors When Structuring Investment Funds
May 2, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will provide guidance on how to structure private equity and other types of funds, taking into account various factors, such as type of investor, type of fund, and location of fund. The presentation will address fund manager issues, as well as fund investor issues. Read More

Tax Planning With Conservation Easements
Structuring Deals After Historic Boardwalk Hall and Other IRS Challenges; Pairing With Oth...
March 7, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will explain the tax advantages and potential tax treatment of conservation easements. The panel will discuss recent case law developments, how to structure easements to avoid IRS challenges, and how to pair conservation easements with the historic tax credit. Read More

Tax Allocation in Partnerships and LLCs
Minimizing Tax Impact Through Strategic Allocation of Income, Gains, Losses and Liabilitie...
February 6, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will provide guidance for tax counsel on tax allocation provisions for partnerships and LLCs taxed as partnerships. The panel will outline steps to meet the tax goals for both the partners and the entity. Read More

Tax Issues for Real Estate Investment Trusts
Structuring REIT Investments and Navigating Tax Treatment of REIT Transactions
January 23, 2013 CLE, CPE CLE On-Demand, Download

This teleconference will provide counsel with a review of federal tax requirements to achieve real estate investment trust (REIT) status, tax structures for REIT investments, and tax treatment of REITs engaging in various transactions. Read More

Attorney-Client Privilege and Work Product in Tax Controversies: Latest Developments
Protecting Confidentiality in IRS Summonses, Taxpayer Accrual Work Papers, FIN 48 Disclosu...
December 12, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax counsel with an analysis of recent developments in the scope of attorney-client privilege and work product for internal corporate tax documents. The panel will outline best practices for protecting the confidentiality of corporate tax documents and shielding from... Read More

Historic Tax Credits: Federal Tax Issues for Investors and Developers
Navigating IRS Qualifications, Structuring Deals After Historic Boardwalk Hall, and Pairin...
November 27, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide counsel with an overview of the historic tax credit, the impact of Historic Boardwalk Hall on current deal terms and structures, and combining with other tax credit programs. The panel will discuss best practices for structuring projects to ensure compliance with IRS... Read More

Tax Issues With Private Equity Management Fee Waivers
Anticipating Areas of IRS Scrutiny and Structuring Defensible Fee Waivers
November 14, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide counsel with a review of the management fee waiver currently being investigated by the New York Attorney General (NY AG), the various ways fee waivers can be structured, the tax risks involved, and best practices for structuring waivers that maximize the chance of wi... Read More

Latest FATCA Reporting and Withholding Developments for 2013
Navigating Complex Requirements for Reporting Foreign Assets
November 6, 2012 CLE, CPE CLE On-Demand, Download

This CLE webinar will discuss the Foreign Account Tax Compliance Act (FATCA) reporting and withholding requirements, including Form 8938 reporting and FATCA withholding obligations. Where relevant, the program will also review continuing Foreign Bank and Financial Accounts Report (FBAR) compliance c... Read More

Tax Challenges for Foreign Investors in U.S. Real Estate
Structuring Investments That Minimize Taxable Income and Capital Gains
October 2, 2012 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide counsel with a review of tax considerations for foreign investors in U.S. real estate, outline best practices for determining the purchasing entity, and review tax planning opportunities in structuring the deal. Read More

Basis Adjustments for Partnerships and LLCs: Tax Law Challenges
Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections
August 21, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will analyze the basis adjustment rules associated with sales, transfers and partnership interests or property distributions; review the impact of the Section 754 election for individual partners and the partnership; and discuss structuring transactions to avoid unintended tax co... Read More

S Corporations: Special Tax Challenges
Confronting the Key Issues of Basis Rules, Business Structure, Payroll-Taxable Wages, Cont...
June 26, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax advisors with an overview of frequently misunderstood and often overlooked tax considerations affecting S Corporations. The panel will explain the key differences between S-Corps vs. LLCs and partnerships. Read More

Section 892 Income Tax Exemption for Sovereign Wealth Funds
Leveraging New Regulations to Avoid Taxation for Commercial Activities
May 1, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax law advisors with a review of pending tax rule changes affecting sovereign wealth funds and other foreign-controlled entities seeking private U.S. investments that won't endanger federal income tax exemption. The panel will offer approaches to avoid exemption-spo... Read More

Cancellation of Debt Income: Tax Consequences
Navigating Section 108 Issues With Debt Discharge and Forgiveness, Loan Modifications, For...
April 24, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax law advisors with a review of the income tax ramifications of debt forgiveness, loan modifications, and the loss of residential property through foreclosure, deed-in-lieu and short sale. Read More

Transfer Pricing for Worldwide Income: New Rules and Enforcement
Transfer Pricing New Rules and Enforcement
April 10, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax counsel with a review of U.S. rules on transfer pricing, provide guidance on efficiently resolving Advance Pricing Agreement issues at the reorganized IRS, and evaluate the new cost-sharing regulations. Read More

Innocent Spouse Relief Under IRC Section 6015
Navigating New Tax Rules to Avoid Liability for Divorced, Widowed or Married Clients
March 13, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax advisors with a review of the scope and elements of the innocent spouse relief rule, filing requirements, and the administrative and appeals process. Read More

IRC Section 707 Transactions Between Partnerships and Their Members
Navigating Disguised Sales Provisions and Avoiding Other Pitfalls Under Anti-Abuse Rules
March 6, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax counsel with a guide to the impact of IRC Section 707 on business transactions between partnerships and partners. The panel will explore the analyses used by the IRS and courts to deem business deals as disguised sales and abusive situations triggering taxable ev... Read More

Taxation of Cross-Entity Mergers and Conversions
Navigating Complex IRS Rules to Merge or Convert LLCs, S Corps and C Corps
February 29, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax counsel with an examination of federal income tax consequences of merging or converting LLCs and partnerships. The panel will provide best practices for entity selection that anticipates long-term business strategies and to structure mergers and acquisitions to o... Read More

Leveraged Partnership Transactions and Tax Opinions Since Canal Corp.
Structuring Transactions and Tax Advisor Engagements to Withstand IRS Scrutiny and Avoid P...
June 22, 2011 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax law advisors an analysis of the Canal Corp. decision, among others, on leveraged partnership transactions, discuss its troubling impact on tax opinion practice, and outline strategies for structuring partnership transactions and tax advisor engagements to withsta... Read More

Mayo Foundation v. U.S.: Supreme Court Applies Chevron Analysis to Tax Cases
Understanding the Implications of Giving Deference to IRS Regulations
March 23, 2011 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax counsel with a review of the Supreme Court's recent Mayo Foundation ruling and its implications for taxpayers. The panel will explore how counsel can prepare for the battle of challenging the validity of a tax regulation amid the uncertainty created by this decis... Read More

Tax Considerations for Joint Ventures
Strategies to Manage Tax Impact When Forming or Exiting a Joint Venture
February 22, 2011 CLE, CPE CLE On-Demand, Download

This CLE teleconference will provide tax counsel with tax considerations when creating, operating and terminating joint ventures. The panel will give special attention to issues involving joint ventures and tax exempt organizations, real estate joint ventures, and joint ventures involving foreign in... Read More

Structuring Tax Provisions in Partnership and LLC Operating Agreements
Effective Allocations With Flow-Through Entities
January 11, 2011 CLE, CPE CLE On-Demand, Download

This CLE webinar will update tax counsel on the key issues to address in operating agreements for partnerships and LLCs taxed as partnerships. The panel will offer best practices for crafting agreements that reflect effective tax compliance and planning going forward. Read More

Advanced Tax Issues in Entity Selection
Choosing the Entity to Meet the Client's Business Strategies and Capital and Compensation...
December 14, 2010 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax counsel with an advanced analysis of legal and financial aspects of business entity structuring, including tax issues related to capital structure and compensation. Our panel will also discuss the impact of new and proposed legislation on tax rates and entity select... Read More

U.S. v. Deloitte: Expansion of Work Product Doctrine in Tax Controversies
Protecting Confidentiality of Internal Tax Documents From the IRS
September 28, 2010 CLE, CPE CLE On-Demand, Download

This CLE webinar will analyze evolving case law on the scope of attorney work product for corporate tax documents; discuss the implications of Deloitte on the protection of tax documents and for the new IRS mandate on reporting of uncertain tax positions; and provide strategies for protecting corpor... Read More

Tax Treatment of Equity Compensation for LLC Members
Structuring Equity-Based Interests for Optimal Tax Outcomes
September 1, 2010 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide tax advisors with an overview of the types of equity interests an LLC can issue and discuss the resulting tax impact for the owner, existing members and the entity. The panel will outline best practices for structuring equity incentive arrangements to optimize tax outco... Read More

Tax Issues in Buy-Sell Agreements
Structuring Agreements for Optimal Income and Estate Tax Results for Partners and Sharehol...
August 11, 2010 CLE, CPE CLE On-Demand, Download

This CLE webinar will prepare tax counsel to address key components of buy-sell agreements, including valuation methodologies and timing, as well as the income and estate tax implications that must be considered in structuring the agreements. Read More

Minimizing Tax in Commercial Loan Workouts and Debt Modifications
Legal Strategies for Reducing Cancellation-of-Debt Income
July 15, 2010 CLE, CPE CLE On-Demand, Download

This CLE webinar will prepare tax counsel to examine the income tax implications of loan workouts and modifications and the impact on the lender and borrower. The panel will outline best practices for managing the tax consequences associated with these transactions. Read More

Economic Substance Doctrine Codified: Surviving Scrutiny Under New IRC Section 7701(o)
Structuring Business Transactions and Understanding the New Audit Landscape
May 19, 2010 CLE, CPE CLE On-Demand, Download

This CLE and CPE webinar will advance the knowledge of tax practitioners regarding the new IRS Code provisions on the economic substance doctrine. The seminar will analyze the impact of the new rules for transactional tax planning and review key case law that may be used to interpret the new rules. Read More

Castle Harbour Decision: Legitimacy of Partnerships With Tax Benefits
Structuring the Entity to Withstand IRS Scrutiny and Maximize Tax Advantages
January 14, 2010 CLE, CPE CLE On-Demand, Download

This CLE webinar will analyze the recent ruling in the Castle Harbour case, its impact on determining the legitimacy of partnership structures with tax benefits, and best practices for structuring partnerships to withstand IRS scrutiny. Read More

Tax Ramifications of Public-Private Partnerships in Infrastructure Projects
Tax Planning Strategies to Maximize Profits in PPP Deals
December 10, 2009 CLE, CPE CLE On-Demand, Download

This CLE seminar will analyze the critical tax planning strategies for structuring public-private partnerships (PPPs), including the federal tax treatment for brownfield versus greenfield projects and state and local tax planning issues. Read More

U.S. v. Textron: Implications for Corporate Taxpayers
Strategies for Protecting Confidentiality of Tax Accrual Work Papers
September 24, 2009 CLE, CPE CLE On-Demand, Download

This seminar will examine the First Circuit's recent reversal in U.S. v. Textron and the implications for business taxpayers. The panel will outline steps counsel can take to protect confidentiality of a company's tax work papers, to the extent still possible. Read More

Attorney-Client Privilege in Tax Controversy and Transactions
Protecting Confidentiality in IRS Summonses, Tax Accrual Work Papers, FIN 48 Disclosures,...
April 30, 2009 CLE, CPE CLE On-Demand, Download

This seminar will examine the attorney-client privilege and exceptions uniquely applicable to tax counsel. The panel will discuss key court cases and offer their experienced perspectives on preserving the privilege and maintaining the confidentiality when providing tax advice. Read More

Section 382 Net Operating Loss Rules
Legal Strategies to Avoid Tax Traps After Change in Corporate Ownership
March 25, 2009 CLE, CPE CLE On-Demand, Download

This seminar will assist the tax practitioner in navigating the Section 382 net operating loss (NOL) rules to maximize utilization of NOL carryforwards and will discuss best practices for companies to take advantage of NOLs in the sale or acquisition of a distressed business. Read More

Tax Planning Strategies for Derivative Financial Products
Leveraging Tax Benefits From Emerging IRS Guidance
February 24, 2009 CLE, CPE CLE On-Demand, Download

This seminar will examine emerging and settled tax issues in the area of derivatives. The seminar will focus on recent developments in tax law relating to these financial products with particular focus on nontraditional derivatives. Read More

China's New Business Income Tax
Shielding Non-China Income From the Expansive Enterprise Income Tax
August 7, 2008 CLE CLE On-Demand, Download

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Uncovering Tax Liabilities in Corporate Due Diligence
Strategies to Deal With Potential Tax Obligations in M&A and Asset Sales
May 29, 2008 CLE

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