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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 ...

Basics of International Taxation 2017 San Francisco

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From the program: Basics of International Taxation 2017

Released on: Sep. 26, 2017

In a global business environment, transactions with customers and suppliers often transcend national borders and investment and activities are frequently cross-border as well.   A working knowledge of the U.S. international tax rules is, therefore, of paramount importance to a wide variety of tax and corporate professionals. This year’s program will be led by international tax experts and focuses on specific types of outbound and ...

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

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

DAVID L. FORST: Start off, Linda? LINDA E. CARLISLE: Yeah, I'll introduce you. OK. Good morning. Welcome to our second day of our mini LLM. Today we're going to focus on inbound investments. We're going to continue our discussion as we drill into transfer pricing, cross-border services, and we'll conclude today with a discussion of what might happen to all the rules that we talked about yesterday and today if international tax reform does take place. To ...

International Tax Aspects of Tax Reform

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

JOHN L HARRINGTON: OK, I'd like to welcome everyone back for the final panel of the day, dealing with international tax acts aspects of tax reform. But before I introduce the panel, I do want to remind you to please, if you haven't already, to fill out the evaluations. Those are very important to us in terms of being able to see what works, what doesn't work, and terms of having a program that's responsive to your needs and interests. So please do ...

Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Passive Investments & U.S. Withholding and Reporting

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: All right. Well, we're back. We're going to now shift from looking at effectively connected income to more passive types of income, and how the United States taxes that type of income in an inbound transaction. Now, to do that, and to explain everything to us, I couldn't be more pleased to have Jamie Null and Jeremy Naylor with us. Jamie is a partner, or shareholder, I think I have to say that correctly, at Greenberg Traurig in ...

Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) – Active Business Operations

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: OK, our first panel is going to deal with the tax concerns for US persons investing or operating outside the United States. Remember, we're using the magic term US persons outside the United States. I'm going to leave and let these people take over, but I'm going to tell you how wonderful they are. Andrea, here. Please sit here. Andrea is one of John's partners. She is a partner at Denton's tax practice in New York, where she has ...

Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) – Lending, Licensing and Portfolio Investments

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

JOHN L. HARRINGTON: We'll start our next panel. And this is on task concerns for US persons investing or operating outside the United States-- lending, licensing, and portfolio investments. And here we're fortunate to have two great panelists. To my right is Ethan Atticks, who is an international tax services managing director in the Washington National Tax Services Office of PWC, where he specializes in outbound international tax issues with a focus ...

Outbound Transfers of Intangible Assets and Treatment of Foreign Currency

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

[MUSIC PLAYING] LINDA E. CARLISLE: Welcome, everyone, back after the break. It was a little bit less than 10 minutes. But we have the panel you've all been waiting for-- the final panel of the day. And it's dealing with outbound transfers of intangible assets and foreign currency. And here we're fortunate in the first part of that to have Jose Murillo, who is national tax partner and leads Ernst & Young International Tax Services Group in Washington ...

International Tax Reporting and Dealing with Noncompliance

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

JOHN L. HARRINGTON: I would like to invite everyone back into the conference room. I hope everyone had a good lunch. And we'll still go through the-- to hear about international tax reporting and dealing with noncompliance. And here again we have two great panelists here. To my right is Bob Temin. He's a partner at the Atlanta tax practice of Rodl Langford de Kock. It's a US affiliate of Rodl & Partner. And Bob's practice focuses on international ...

Overview of U.S. International Tax System

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: We'll first start with a general overview of the US international tax system and even though I just said we have preeminent tax lawyers explaining everything to you, John and I are going to start off, OK. So we will, maybe not the most preeminent, but we will start it off so that the preeminent people can elaborate. JOHN L. HARRINGTON: I mean, some of this will be quite basic. I mean some of these will be familiar to you but the ...

Cross-Border Services and Employment Tax Issues

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: --it. Because now we're going to talk about cross-border services and employment tax issues. Now, this is, to me, something that is not discussed, but at least has come up in my practice way too many times and I haven't known what to do, OK? But that is the reason I've got Candace Ewell here and I've got Narendra Acharya here. Narendra to my right-right is a partner in the Chicago office of Baker and McKenzie and member of the firm's ...

Advanced Swaps & Other Derivatives 2017 -- New Withholding Regulations on Cross-Border Equity Derivatives and Related Developments

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From the program: Advanced Swaps & Other Derivatives 2017

Recorded on: Oct. 26, 2017

Taken from the Web Program Advanced Swaps & Other Derivatives 2017 recorded October 2017 in New York. New Withholding Regulations on Cross-Border Equity Derivatives and Related Developments [01:01:26] New regulations on the taxation of dividend equivalents paid in cross-border swaps and on equity-linked instruments IRS temporary regulations on deemed loans embedded in off-market and exchange-cleared swaps The new Qualified ...

New Withholding Regulations on Cross-Border Equity Derivatives and Related Developments

Transcripts  Transcripts    

Recorded on: Oct. 26, 2017

JOSHUA COHN: Welcome back. We're going to get going again. Hope you enjoyed your lunch. We're now going to turn to new withholding regulations on cross-border equity derivatives and related developments. And we have with us Mark Leeds and Michael Mann. Mark is a tax partner with Mayer Brown. His professional practice focuses on the tax consequences of a variety of capital markets products, and strategies, including over-the-counter derivative transactions, ...

Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017

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From the program: Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017

Released on: Nov. 1, 2017

This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from relatively simple single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. Evolving techniques for structuring, financing, ...

Overview and Strategies in Representing Sellers

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

LOUIS S. FREEMAN: Thanks for the reference the Illinois. Actually, I decided to move to Florida when we were visiting. And there was an art fair, and it was a large crowd I got in line to go to a luncheonette, and it was a long line. This is February. And I came up at the end, and two guys from New York came up at the same time. I said, you go ahead. I'm not in any rush. And they said, oh, that's OK. You go ahead. We can't leave till June 1. You get ...

Planning for Private Equity and Hedge Fund Investments

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

ERIC SOLOMON: Good morning, good morning, good morning. Welcome back for our third day. We're going to start with a discussion of planning for private equity and hedge fund investments. And let me introduce our panel. To my immediate left is David Schnabel. David is a partner at Davis Polk in the tax department. He advises clients on a full range of transactions, including M&A, spinoffs, financing, partnership, and other flow-through investments, ...

Corporate Tax Strategies and Techniques Using Partnerships, LLCs and Other Strategic Alliances

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

LINDA CARLISLE: All right, we're heading into the last two panels for our first day and, yes, these have all been fantastic today and we've got two more that are going to be equally as fantastic. Right now we're going to talk about the use of pass-through corporations and LLCs, partnerships, in M&A transactions. And to do that we have two of the best people I can think of to lead us in this discussion. To my left is my very good friend Blake Rubin. ...

Selected Seller and Buyer Issues, Including Negotiating and Drafting Tax Provisions in Acquisition Agreements

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

LINDA CARLISLE: OK now we learned everything there is to know about the things that we have to keep in mind with the selling shareholder. And I'm so pleased, our next panel is going to tell us how to structure the paper work that helps us develop a taxable and a nontaxable transaction. And to do that, I've got three of the greatest people I know, Bill Cavanaugh, Rick Reinhold, and Phil Wright. OK, Bill-- to my left, left-- is co-chair of Norton Rose ...

Corporate Transactions Open Discussion

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

ERIC SOLOMON: Good morning, everybody. AUDIENCE: Good morning. ERIC SOLOMON: Good morning, Mark. Our next session is a discussion of what's on your minds. This is an opportunity for you to ask about any corporate tax issues or any other issues. It could be personal issues, family issues, romantic issues. Of course, you got to know who you're getting advice from. [LAUGHS] But in any event, this is your opportunity to talk about corporate tax issues. ...

Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Ethics Issues

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

ERIC SOLOMON: Let me introduce the panel. First, to my immediate left, is Michael Desmond. Michael is a sole practitioner at The Law Offices of Michael J. Desmond. Mike started as a trial attorney with the Attorney General's Honors Program at the Tax Division of the US Department of Justice. Then, he worked at a boutique law firm, where he was made partner. And I'm guessing that's McKee Nelson? MICHAEL J. DESMOND: That's correct ERIC SOLOMON: All ...

State and Local Tax Issues in Corporate M&A Transactions

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

ERIC SOLOMON: First to my immediate left is David Shipley. He's a partner with McCarter and English. And he's a frequent speaker on multi-state tax topics. And he writes frequently on multi-state tax issues. So welcome, David. And then next to David is Peter Faber. Peter is a partner in the New York office of the law firm of McDermott, Will, and Emory LLP. He specializes in state and local tax matters. He formally served as chairman of the American ...

Interesting Corporate Transactions of the Past Year

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

ERIC SOLOMON: Our next panel is interesting transactions of the past year. And I am pleased to introduce my co-chair of this program, Linda Carlisle. Linda is the chief operating officer and general counsel of Unicom Capital LLC in Denver. Linda was formerly a member of Miller and Chevalier in Washington before joining Unicom, and at Miller and Chevalier she practiced international and domestic tax law. Before joining Miller and Chevalier, Linda ...

Structuring Leveraged Buyouts

Transcripts  Transcripts    

Recorded on: Oct. 27, 2017

LINDA CARLISLE: Well, welcome back. We have one more panel before lunchtime, and this one will whet our appetite. There is no if, ands, or buts about it. We are going to be talking about structuring leveraged buyouts. Remember, this was something that Lou talked about in our overview first this morning. And to do this, I couldn't be more pleased to have these three people with me. I'll start all the way to my left, left, left is Kevin Keyes. Kevin ...

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

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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 ...


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