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Section 336(e) Elections: Tax Basis Step Up Through Deemed Asset Sale Treatment

Structuring Qualifying Stock Dispositions for Partnership and Private Equity Acquirers

*** This is an encore presentation. This presentation is not eligible for CLE credits in Mississippi or CPE credits. ***

Tuesday, November 21, 2017

The "Fractions Rule" in Partnership Agreements: Drafting Section 514(c)(9)(E) Compliant Allocations

Avoiding UBTI Triggers Through Savings Clauses and Other Structuring Tools

Tuesday, November 28, 2017

Form 5471 Substantial Compliance Rules: New IRS International Practice Unit Guidance

When Will the IRS Deem An International Tax Information Filing as Not "Substantially Complete"?

*** An encore presentation featuring live Q&A ***

Thursday, November 30, 2017

IRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Entities for Tax Arbitrage

Lowering U.S. Income Tax on Income From Eligible Foreign Entities by Electing Tax-Advantaged Treatment

Tuesday, December 5, 2017

Private Equity Management Fee Waivers Under Heightened IRS Scrutiny: Minimizing Audit Risks

Reviewing Fee Arrangements to Avoid Re-Characterization of Profits Interests

Tuesday, December 12, 2017

Recent Tax Law Webinars

Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and Appeals

Conducted on November 1, 2017

Form 5471 Substantial Compliance Rules: New IRS International Practice Unit Guidance

When Will the IRS Deem An International Tax Information Filing as Not "Substantially Complete"?

Conducted on October 24, 2017

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Strafford's CLE programs are designed exclusively by attorneys, under the guidance of distinguished advisory boards, and presented by a panel of carefully selected attorneys with critical knowledge of the issues presented.

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About Strafford Webinars

Strafford webinars offer an excellent opportunity to train your entire staff—with no lost travel time or expenses.

Each live webinar features presentations by a panel of nationally recognized authorities, followed by an interactive Q&A session. In most cases, presentation materials can be viewed online or printed out and audio can be accessed via the web or a telephone.

Continuing Legal Education

Strafford programs qualify for CLE credits in every state that accredits webinars.

They offer you a high quality, cost effective, and convenient CLE option, with no lost travel time or expenses.

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Shire Canada

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