Seminar  Program

2017 Tax Act Update: Riding the Tidal Wave of Regulatory and Administrative Guidance


Select a Location:

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute

New York City Seminar Location

PLI New York Center
, 1177 Avenue of the Americas, (2nd floor), entrance on 45th Street, New York, New York 10036. (800) 260-4754.

New York City Hotel Accommodations

Crowne Plaza Times Square Manhattan, 1605 Broadway (48th Street), New York, NY 10019 (212) 977-4000. When calling, mention Practising Law Institute. You can also make reservations online to access PLI's rates.

The Muse, 130 West 46th Street, New York, NY 10036. Please call reservations at 1-800-546-7866. When calling, please mention Practising Law Institute and Corporate Rate ID 786839408. In addition, you can book online at PLI Muse Hotel

Millennium Broadway Hotel, 145 West 44th Street, New York, NY 10036. Please call reservations at 1-800-622-5569. When calling, please mention Practising Law Institute. In addition, you can book online at PLI Millennium Hotel .

 Hyatt Times Square, 135 W. 45th Street, New York, NY 10036. For reservations, please call (646) 364-1234. When calling mention rate code CR56218 or Practising Law Institute.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama: PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live seminars qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

California:  PLI’s live seminars qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Illinois: All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Iowa:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Kansas:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Louisiana:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Maine:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Minnesota:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Mississippi:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Missouri:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Montana:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Nebraska:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Nevada:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

New Mexico:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live seminars can be used to fulfill the requirements for newly admitted attorneys. All credit categories may be earned via transitional live seminars.

North Carolina:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars

North Dakota:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Ohio:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Oklahoma:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania: PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

South Carolina:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Tennessee:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Vermont:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live seminars qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Wisconsin:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

Wyoming:  PLI’s live seminars qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live seminars.

CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live seminars qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live seminars qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC): PLI’s live seminars can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live seminars qualify as “live” credit. There is no limit to the number of points an attorney can earn via live seminars.

United Kingdom (CPD-UK):  PLI’s live seminars can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live seminars qualify as “live” credit in all Australian jurisdictions. There is no limit to the number of credits an attorney can earn via live seminars.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live seminars may fulfill CLPD credit requirements.

Other Credit Types

CPE Credit (NASBA): PLI’s live seminars qualify as the “Group-Live” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE): PLI’s live seminars may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live seminars may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live seminars may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live seminars may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live seminars qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live seminars qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live programs.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live seminars may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live seminars may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live seminars may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live seminars may fulfill CFP credit requirements.

 

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.

PLI’s live and on-demand webcasts are single-user license products intended for an individual registrant only. Credit will be issued only to the individual registered. If two or more individuals wish to participate in a webcast and receive credit, PLI would be happy to provide a Groupcast – group viewing of a webcast. To schedule a Groupcast, please contact PLI at groupcasts@pli.edu.


U.S. MCLE States

Alabama:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live webcasts qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

California:  PLI’s live webcasts qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live webcasts qualify as “eCLE” credit. Attorneys are limited to 12 credits of eCLE per reporting period.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live webcasts qualify as “in-house” credit. Attorneys are limited to 6 in-house credits per reporting period.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live webcasts qualify as “distance education” credit. Attorneys are limited to 9 credits of distance education per reporting period. Effective January 1, 2019, the limit of distance education per reporting period will increase from 9 to 18 credits.

Iowa:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Kansas:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Kentucky:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Louisiana:  PLI’s live webcasts qualify as “self-study” credit. Attorneys are limited to 4 credits of self-study per reporting period.

Maine:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Minnesota:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Mississippi:  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Montana:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Nebraska:  PLI’s live webcasts qualify as “computer-based learning” credit. Attorneys are limited to 5 credits of computer-based learning per reporting period.

Nevada:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live webcasts qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live webcasts can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live webcasts. Skills credits may not be earned via live webcasts.

North Carolina:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

North Dakota:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Ohio:  PLI’s live webcasts qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Oklahoma:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

South Carolina:  PLI’s live webcasts qualify as “alternatively delivered” credit. Attorneys are limited to 6 credits of alternatively delivered programs per reporting period.

Tennessee:  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 8 credits of distance learning per reporting period.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live webcasts qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live webcasts qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live webcasts qualify as “online” credit. Attorneys are limited to 12 credits of online instruction per reporting period.

Wisconsin:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

Wyoming:  PLI’s live webcasts qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live webcasts.

CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live webcasts qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live webcasts qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live webcasts can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live webcasts qualify as “distance learning” credit. Attorneys are limited to 15 points of distance learning programs per reporting period.

United Kingdom (CPD-UK):  PLI’s live webcasts can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live webcasts may fulfill Australia’s CPD requirements. Credit limits for live webcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live webcasts may fulfill CLPD credit requirements.

Other Credit Types

CPE Credit (NASBA):  PLI’s live webcasts qualify as the “Group-Internet-Based” (GIB) delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s live webcasts may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live webcasts may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live webcasts may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live webcasts may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live webcasts qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live webcasts qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live programs.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live webcasts may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live webcasts may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live webcasts may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live webcasts may fulfill CFP credit requirements.

 

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
Cleveland Groupcast Location

The Cleveland Metropolitan Bar Association, 1375 E. 9th Street – Floor 2, Cleveland, Ohio 44114. 216-696-2404.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as the “Group-Live” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CFP credit requirements.

 

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
Columbus Groupcast Location

Columbus Bar Association, 175 S. Third Street, Suite 1100, Columbus, OH 43215. Phone: 614-221-4112, FAX: (614) 340-2081.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as the “Group-Live” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CFP credit requirements.

 

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute

Boston Groupcast Location

MCLE | New England, 10 Winter Place, Boston, Massachusetts 02100. (617) 350-7006.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as the “Group-Live” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CFP credit requirements.

 

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
New Jersey Groupcast Location

New Jersey Institute for Continuing Legal Education, One Constitution Square, New Brunswick, NJ 08901-1520. 732-249-5100.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as the “Group-Live” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CFP credit requirements.

 

Why You Should Attend

The significant changes made by the 2017 Tax Act impact virtually every business and their owners. The Treasury Department and Internal Revenue Service have been busy working on guidance to implement the many novel provisions.  The guidance answers many of the questions raised by the statutory language, but many issues remain. At this full-day program, our faculty of recognized tax experts will analyze and discuss the tax law changes and guidance.  

What You Will Learn

  • Recently issued Treasury and Internal Revenue Service guidance on many of the Act’s provisions
  • The impact of the Act’s provisions on businesses and individuals
  • The impact of the Act’s provisions on transaction planning

Plus you will have the opportunity to have your questions answered by our expert faculty throughout the program.

Who Should Attend

This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of these fundamental changes to the U.S. tax system. 

 

Program Level – Overview 

Intended Audience – Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the impact of the 2017 Tax Act on U.S. and international tax law and practice.

Prerequisites – An interest in exploring the latest legislative, regulatory and judicial developments following the passage of the 2017 Tax Act.

Advanced Preparation – None


PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

9:00 Opening Remarks
David H. Schnabel, Karen Gilbreath Sowell

9:15 The New Infrastructure for Taxing Controlled Foreign Corporations (“CFCs”)
• Overview of the global intangible low-taxed income (“GILTI”) rules, including the proposed GILTI regulations and interaction with foreign tax credit (“FTC”) rules
• Treatment of individuals and passthroughs under the GILTI rules
• Application of the interest expense limitation rules under Section 163(j) at the CFC level
• Operation of the Section 245A dividends received deduction, including the anti-hybrid rules under Section 245A(e)
Michael J. Caballero, Margaret O’Connor (Invited), Dana L. Trier, Christopher Trump

10:15 Basis and Earnings and Profits (“E&P”) Consequences of the New Tax System
• Analysis of CFC basis adjustments required by GILTI and Section 965 regulations and potential alternative systems 
• Previously taxed income (“PTI”) issues raised by new categories of income and significance of amount of PTI in the system
• Application of Section 1059
Andrew M. Herman, John J. Merrick (Invited), Karen Gilbreath Sowell, Gordon E. Warnke, Brenda L. Zent (Invited)

11:15 Networking Break

11:30 Application of the 2017 Tax Act Provisions to Consolidated Groups
• Business interest expense limitations in Section 163(j)
• Expensing provisions of Section 168(k)
• International provisions of the Tax Act (e.g., GILTI, FDII, and BEAT) and proposed regulations related to these provisions
Bryan P. Collins, Marc A. Countryman, Marie C. Milnes-Vasquez (Invited), Michael L. Schler

12:30 Lunch

1:45 Base Erosion Anti-Abuse Tax (“BEAT”) and Foreign Tax Credit (“FTC”) Rules
• Assessing whether a taxpayer is in or out of the BEAT
• BEAT and the law of unintended consequences
• FTC baskets and allocation of expenses
Kimberly S. Blanchard, Jesse F. Eggert, Daniel M. McCall (Invited), S. Eric Wang 

2:45 Partnership Issues under the 2017 Tax Act
• Application of the business interest expense limitation of Section 163(j) in the partnership context
• Operation of Sections 864(c)(8) and 1446(f) to partnership interest transfers
• Section 168(k) and partnership transactions 
• Ownership of foreign corporation (including GILTI, FDII and Section 862 elections)
Pamela Lawrence Endreny, David H. Schnabel, Michael B. Shulman, Clifford M. Warren

3:45 Networking Break

4:00 Provisions of the 2017 Tax Act Affecting Real Estate: Qualified Opportunity Zones
• Properly structuring a qualified opportunity zone project or business, including timing and entity issues
• The gains that qualify and the technical requirements of the rules
• Who is currently benefitting from the rules
• Open issues under the latest IRS guidance
Robert Cassanos, Erin Cleary, Russell G. Jones (Invited), Jonathan Talansky, Thomas C. West, Jr.

5:00 Adjourn

Co-Chair(s)
David H. Schnabel ~ Davis Polk & Wardwell LLP
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Michael J. Caballero ~ Covington & Burling LLP
Robert Cassanos ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Erin Cleary ~ Debevoise & Plimpton LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jesse F. Eggert ~ KPMG LLP
Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP
Russell G. Jones ~ Senior Counsel; Office of the Associate Chief Counsel (Corporate), Branch 3, Internal Revenue Service
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Margaret O'Connor ~ Deputy Associate Chief (Operations and International Programs), Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael L. Schler ~ Cravath, Swaine & Moore LLP
Michael B. Shulman ~ Shearman & Sterling LLP
Jonathan Talansky ~ King & Spalding
Dana L. Trier ~ Davis Polk & Wardwell LLP
Christopher Trump ~ Deloitte Tax LLP
S. Eric Wang ~ Sullivan & Cromwell LLP
Gordon E. Warnke ~ KPMG LLP
Clifford M. Warren ~ Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Program Attorney(s)
Stacey L. Greenblatt ~ Senior Program Attorney, Practising Law Institute
Atlanta Groupcast Location

Atlanta Bar Association, 400 International Tower, 229 Peachtree Street, NE, Atlanta, GA 30303-1601. (404) 521-0781.

General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.


U.S. MCLE States

Alabama:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Alaska:  All PLI products can fulfill Alaska’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Arizona:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

California:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

Colorado:  All PLI products can fulfill Colorado’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Florida:  All PLI products can fulfill Florida’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Georgia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Hawaii:  All PLI products can fulfill Hawaii’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Idaho:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Iowa:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Kansas:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live programs.

Kentucky:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Louisiana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Maine:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Minnesota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Mississippi:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

Missouri:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Montana:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nebraska:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Nevada:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New Hampshire:  All PLI products can fulfill New Hampshire’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

New Jersey:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can be used to fulfill the requirements for New York newly admitted attorneys. Ethics credit, professional practice credit, and law practice management credit may be earned via transitional live groupcasts. Skills credits may not be earned via live groupcasts.

North Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

North Dakota:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Ohio:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oklahoma:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Oregon:  All PLI products can fulfill Oregon’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Pennsylvania:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Puerto Rico:  All PLI products can fulfill Puerto Rico’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Rhode Island:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

South Carolina:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Tennessee:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live interactive” credit. There is no limit to the number of credits an attorney can earn via live interactive programs.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wisconsin:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.

Wyoming:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of credits an attorney can earn via live groupcasts.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “real-time” credit. There is no limit to the number of credits an attorney can earn via real-time programs.

Ontario (CPD-ON):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “interactive” credit. There is no limit to the number of credits an attorney can earn via interactive programs.

Quebec (CPD-QC):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” credit. There is no limit to the number of points an attorney can earn via live groupcasts.

United Kingdom (CPD-UK):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Australia’s CPD requirements. Credit limits for live groupcasts vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as the “Group-Live” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as "instructor-led" credit. There is no limit to the number of credits an SHRM professional can earn via instructor-led programs.

Compliance Certification Board (CCB):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) qualify as “live” training events. There is no limit to the number of credits a candidate or certification holder can earn via live groupcasts.

Certified Anti-Money Laundering Specialists (CAMS):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CAMS credit requirements.

New York State Social Worker Continuing Education (SW CPE):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill SW CPE credit requirements.

American Bankers Association Professional Certification (ABA):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s live groupcasts (i.e. live webcasts available for group viewing at co-sponsored locations) may fulfill CFP credit requirements.

 

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