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Showing 1 - 25 of 116 Results


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Nuts and Bolts of Tax Penalties 2017: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties

On-Demand Web Programs  On-Demand Web Programs    

From the program: Nuts and Bolts of Tax Penalties 2017: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties

Released on: May. 3, 2017

The number of accuracy-related penalties assessed against individual taxpayers increased from 58,366 in 2005 to 553,184 in 2015.  That is nearly a 1,000% increase over the past decade!  Are there more bad taxpayers?  Or, is the IRS just getting more aggressive about asserting penalties?  Regardless of the answer, responsible tax practitioners must understand what triggers a penalty assessment and how to protect their clients and ...

Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments

MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

Recorded on: Jul. 20, 2017

Taken from the Web Program Recorded July 18 - 19, 2017 in New YorkTax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments [01:32:34]• Effectively Connected Income (ECI) and permanent establishment consequences • Branch profits tax imposition John D. Bates, S. Eric WangThe purchase price of this Web Program segment includes the following article from the Course Handbook available ...

Mergers & Acquisitions 2018: Advanced Trends and Developments -- Federal Tax Considerations in M&A

Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: Mergers & Acquisitions 2018: Advanced Trends and Developments

Recorded on: Jan. 16, 2018

Taken from the Web Program Mergers & Acquisitions 2018: Advanced Trends and Developments Recorded January 2018 in New York Federal Tax Considerations in M&A [01:30:05] Taxable acquisitions Tax-free reorganizations Inversions Spin-offs and split-offs, including "Morris Trust" and "Reverse Morris Trust" transactions Section 382 and NOL rights plans Stuart M. Finkelstein (CPE Field of Study: Taxes) (IRS ...

Federal Tax Considerations in M&A

Transcripts  Transcripts    

Recorded on: Jan. 16, 2018

KEVIN MILLER: Well, welcome back, everybody. As promised, we have the highlight of the day, Stuart Finkelstein from Skadden, Arps. He's the co-global head of tax at Skadden, advises some of the world's largest and most active M&A companies, and is obviously an expert in the field. But two things I'd like to highlight about him that I think are most important is one, a U of M grad, both undergrad and law school. STUART FINKELSTEIN: Go Blue. KEVIN ...

Taxation of Financial Products and Transactions 2018

On-Demand Web Programs  On-Demand Web Programs    Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: Taxation of Financial Products and Transactions 2018

Released on: Jan. 23, 2018

Although tax reform remains on the horizon, existing law continues to pose many challenges for taxpayers and their advisers. The new regulations under Section 987, the sometimes-baffling operation of Section 988, and a recent challenge to the validity of the final regulations under Section 956 have sent tax professionals searching for guidance.  This year’s program has been completely redesigned to help you understand the latest changes ...

FX Issues (Including Straddles)

Transcripts  Transcripts    

Recorded on: Jan. 17, 2018

MATTHEW A. STEVENS: OK. Welcome back. I'm still Matthew Stevens, in case you've forgotten that. And with me is the next panel on the post regulations that impact Section 988 transactions and other 988 issues. If you found the first half of the previous panel to be a little bit too deep of a dive into the 954 hedging regulations, this panel is going to explore those and we will attempt to stay within snorkeling depth of that. So I need to ask you ...

Financial Transactions in M&A

Transcripts  Transcripts    

Recorded on: Jan. 17, 2018

MATTHEW A. STEVENS: And we are back for our afternoon's panels. The next panel is a domestic product panel, not tremendously affected by the recent tax legislation, financial product issues in M&A transactions, and your moderator is Eileen Marshall, who is a partner at Wilson, Sonsini, Goodrich, and Rosati. And I understand you regularly speak with Mr. Rosati? EILEEN MARSHALL: More frequently with Mr. Sonsini. MATTHEW A. STEVENS: Oh, she's even ...

Financial Products Issues Under the Final Section 987 Regulations

Transcripts  Transcripts    

Recorded on: Jan. 17, 2018

LEE HOLT: So again, given that the subsequent panel will go into these regs a fair bit -- having said that, I do just want to briefly provide an overview or summary of what is in the reg package, and then again what we'll focus on. Lot of words on the slide, but let's just highlight a few things here. So, in case you missed it, and I don't know why you would have, on December 19 there might have been something called tax reform going on. But, in ...

Section 956: Issues and Solutions

Transcripts  Transcripts    

Recorded on: Jan. 17, 2018

MATTHEW A. STEVENS: OK, welcome back. Here with our third panel, which deals with Section 956 issues and solutions. Section 956 has a much different role to play in the US international tax system than it did last summer when I first approached Kim about doing this panel. And so we need an engagement question, or a pulse question. So I'll ask the audience-- and I have a prediction about how many hands I'll see-- how many people understand the role ...

Distressed Debt Issues: Is the Market Creating a Coherent Regime?

Transcripts  Transcripts    

Recorded on: Jan. 17, 2018

MATTHEW A. STEVENS: OK. So our next panel is going to provide an update on the tax treatment of distressed debt and I will ask my engagement question before introducing Mr. Leeds, the moderator of the panel. The engagement question is, again, by the now notorious show of hands, how many people in the room believe that the recent Tax Reform Act affected the tax treatment of distressed debt transactions? OK. So only a couple of hands went up, most people ...

The Unrelated Business Income Tax: Issues for Hedge Fund Managers

Transcripts  Transcripts    

Recorded on: Jan. 17, 2018

MATTHEW STEVENS: Thanks, Daisy. Thanks for coming back, or hanging in there for our last panel of the day, which deals with the application of the unrelated business income tax for hedge fund managers. There's been a fair amount of discussion about the UBIT generally. But we in the financial products tax world have not tended to focus on it. And it seems to be something of an afterthought even for folks whose practice does tend to focus on asset management. ...

The Tax Cuts and Jobs Act: Navigating the New Landscape

On-Demand Web Programs  On-Demand Web Programs    Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: The Tax Cuts and Jobs Act: Navigating the New Landscape

Released on: Feb. 12, 2018

Seeking CPE credit (NASBA QAS Self-Study)? CPE credit is available for each segment of the program. Click on the respective link below to access each individual on-demand segment. CPE credit is available by completing and passing the segment’s CPE Review & Exam. The Tax Cuts and Jobs Act effects the most significant changes to the Internal Revenue Code since the overhaul in 1986.  The changes impact virtually every ...

The International Tax Reform Provisions—Part 1

Transcripts  Transcripts    

Recorded on: Feb. 5, 2018

DAVID H. SCHNABEL: So just introduce the first panel, Neil Barr, my partner at Davis Polk is going to moderate it. Joining Neil will be John Harrell, who is the global tax director at GE Capital, Aaron Junge, a tax counsel the House Ways and Means is joining via webcast. Marjorie Rollinson, Associate Chief Counsel International is also here, as well as Brenda Zent, Special Advisor to the International Tax Counsel. And of course, Dana. So Neil, you ...

The International Tax Reform Provisions—Part 2

Transcripts  Transcripts    

Recorded on: Feb. 5, 2018

DAVID SCHNABEL: OK, I think we're going to get started with our second international panel. Just to introduce the people, we have two people joining via video, Jennifer Acuna, who's a Senior Tax Counsel and Policy Adviser at the Senate Finance Committee. We've got Manal Corwin, who has the coolest title of all. She's at KPMG and is the National Service Line Leader for International Tax as well as the principal in charge of the Washington National ...

Tax Reform Provisions Impacting Domestic Businesses and Pass-Through Entities

Transcripts  Transcripts    

Recorded on: Feb. 5, 2018

DAVID H. SCHNABEL: OK, I think we're going to start the final panel now. Joining me up here is, again, Dan Trier. He's the Deputy Assistant Secretary of Tax Policy at Treasury and master of all things tax reform. Eric Sloan is also here. He's a tax partner at Gibson, Dunn. And via video, we have Mark Prater. Mark is the Deputy Staff Director and Chief Tax Counsel for the Senate Finance Committee, and I think was there when a lot of the provisions ...

20th Annual Real Estate Tax Forum

On-Demand Web Programs  On-Demand Web Programs    

From the program: 20th Annual Real Estate Tax Forum

Released on: Feb. 6, 2018

Our 20th Anniversary program will continue to focus on transactions, highlighting the tax problems encountered by practitioners in today’s typical commercial real estate transactions and structures, and examining the simple and sophisticated solutions being used by the experts.  Panels of nationally-recognized real estate tax experts from major law and accounting firms will provide attorneys, accountants and real estate professionals with ...

International Tax Issues 2018

On-Demand Web Programs  On-Demand Web Programs    Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: International Tax Issues 2018

Released on: Feb. 13, 2018

As the world’s economies grow increasingly integrated through trade, acquisitions and joint ventures, U.S. international tax laws impact a greater percentage of businesses and transactions.  These international tax rules just went through substantial revisions with the passage of U.S. tax reform at the end of 2017.  These new international tax rules affect not only large U.S. and non-U.S. based multinationals, but also affect mid-sized ...

Foreign Tax Credits and Subpart F Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL DIFRONZO: Hey, welcome back. Our panel is going to continue with the tax reform theme. As I've mentioned before the break, this panel will focus on guilty, It'll also focus on foreign tax credits and some of the other nuances that have already been introduced of these rules, but they're going to dive a little deeper. And I'm very, very pleased to introduce what I consider to be an all-star panel for this. To my immediate left is Chris Trump, ...

Inbound Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL A. DIFRONZO: So this is an exciting time. I'm going to begin by introducing the first panel, but we have the other subject areas. And I'll introduce them as they come through. This first panel is going to talk about inbound issues-- will focus a lot on tax reform. I do think they'll mention a few other things, like FIRPTA and BEPS or something along the way, but I think much of what they have to say will be about tax reform. So to introduce ...

Developments on Transfer Pricing

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL DIFRONZO: OK, so are in our next panel will cover transfer pricing. And they'll make their way up here. Then I'll introduce them. But it's going to be a little different when we talk about transfer pricing, I think, today. No, two Toms. Who's opening? OK. So as they're getting seated, I'm going to introduce them. Rocco Femia is immediately to my left. Rocco is with Millard Chevalier. Rocco served in the United States Treasury International ...

Cross-Border Partnership Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL A. DIFRONZO: OK, thank you, Stacy. So we're in the final stretch here, and we've got maybe even a just as complicated topic to discuss as the last one, which is how does all of this shake out in the triangle world or the pass-through world. And also, there are a number of old issues that are still hot in that space. So this panel's going to take us through-- I'm not going to take much of their time. We only have an hour 14 right now to get ...

Cross-Border M&A Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MARJORIE A. ROLLINSON: It's good to [INAUDIBLE]. MICHAEL A. DIFRONZO: Welcome back. Now we're going to move into our M&A panel. And I would like to introduce our panelists again, starting right to left. I'm pleased to introduce Margie Rollinson. Margie Rollinson is the Associate Chief Counsel International. She has a very, very big job ahead of her this year. Got to write a lot of guidances, really going to help us get through these very complicated ...

Consolidated Tax Return Regulations 2018

On-Demand Web Programs  On-Demand Web Programs    Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: Consolidated Tax Return Regulations 2018

Released on: Feb. 28, 2018

During the past twenty-six years, the Department of the Treasury and the Internal Revenue Service have substantially revised the consolidated return regulations. These changes, coupled with legislative developments, judicial decisions, and published and private rulings, have dramatically changed the operating rules of consolidated returns. An understanding of these rules is critical for practitioners and corporate tax counsel who practice in this ...

Unified Loss Rules

Transcripts  Transcripts    

Recorded on: Feb. 22, 2018

MARK SILVERMAN: Welcome back. I hope everyone had a great lunch and the Ax got you the Woody Allen. A pound of corned beef, a pound of pastrami. Best sandwich in the world. OK, we're going to move on to our next session, and that's the Unified Loss Rules, dash 36 and related questions. So for that, let me introduce the distinguished panel to you. On my far left is Marc the Countryman. He's the national office of E&Y, though he's located in San Francisco. ...

Investment Adjustments and Related Issues

Transcripts  Transcripts    

Recorded on: Feb. 22, 2018

MARK J. SILVERMAN: Yeah, that's true. I forgot I we were intentionally doing that. OK. So the first topic is going to be basketball. So I want to know who, you're aware of who's a tax person, guarded Meadowlark Lemon? Does anyone in the room know who Meadowlark Lemon is? Oh excellent. OK, good. OK so does anybody know the answer to that question? You can tell me later. Right it down. Oh, Stacy, who is it? AUDIENCE: Will Dixon. MARK J. SILVERMAN: ...


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