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IRS and Treasury’s New Guidance Issued Under Sections 7874 and 385

MP3 Audio  Audio Download (MP3)    On-Demand Web Briefing  On-Demand One-Hour Briefing    

Recorded on: Apr. 29, 2016

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Lecture Topics [01:01:32] Upon the successful completion of this program, the participant will be able to: Understand inversion transactions and the potential impact on certain-publicly traded companies stemming from federal regulation of inversions. Recall the New Provisions under section 7874 impacting inversion ...

Last Lunch from a Hot Dog Stand — A Discussion of Recent IRC Section 355 Guidance

MP3 Audio  Audio Download (MP3)    On-Demand Web Briefing  On-Demand One-Hour Briefing    

Recorded on: Aug. 18, 2016

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Lecture Topics [01:07:55] Upon the successful completion of this program, the participant will be able to: Recall the existing rules concerning tax-free distributions pursuant to IRC Section 355. Recognize the workings of the new proposed rules concerning IRC Section 355 as they relate to the active trade or business (ATB) ...

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 Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2017

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: Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2017

Released on: Jun. 24, 2017

This three-day seminar has been designed to ensure that all will benefit, from beginners to experts. The first two days will present a logical and comprehensive study of the basic framework and many important intricacies of Subchapter K, an area of the tax law that many believe can be understood only in its totality. The third day will focus on the application of partnership taxation to specific industries, including oil and gas, hedge funds and private ...

Economic Substance, Judicial Doctrines and Legal Ethics

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

CLIFFORD WARREN: Great panel. One of the more interesting topics, I think, in the three days, but not nearly as interesting as the following panel. Because this panel has ethics. And it's credit time for a lot of people who need them. As we all know, partnerships have taken a bit of a beating in the courts over the last decade, which makes it very important for tax lawyers and accountants to be aware of the various judicial doctrines and ethical issues. This ...

Advanced Topics in Joint Venture Formations

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

STEPHEN ROSE: As we all know, it's been a long time since partnerships were used only to hold real estate, or to practice law or accounting. Partnerships are now the vehicle of choice for operating businesses. To focus on the partnership formation issues, particularly those involving joint ventures of operating businesses, we have Phillip Gall and Don Rocap. Phillip is a principal in the Partnership Transaction Planning and Economics Group in Ernst ...

Transactions Between Partner and Partnership – Sections 707, 704(c)(1)(B), 731, and 737

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

CLIFFORD WARREN: Well good morning, everyone. Welcome back. I hope you enjoyed the first day, we've got a good day ahead of us on Subchapter K. I know what you're thinking. You're thinking that does not look like Jenny, and you're right. It's Eric Sloan, who's going to be sitting in for Jenny, who had transportation issues getting here. And I'll introduce Eric's co-speaker in a moment. But Subchapter K is strewn with land mines and other problems, ...

Implications of Section 704(c) for Negotiating a Partnership Agreement

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

STEPHEN ROSE: I'm going to start the introductions while people are getting settled just to-- BEVERLY KATZ: Just so you get absolutely no break. STEPHEN ROSE: Yes, exactly. No break whatsoever. So at this point, we're going to continue on with our consideration of the determination of a partner's distributive share. And if you enjoyed the complexity of the Section 704(b) regulations, you're going to love the Section 704(c) regulations. For the ...

Partnership Mergers and Divisions

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

STEPHEN D. ROSE: So our next program focuses on partnership mergers and divisions. As you'll learn, the regulations under 708(b)(2) are full of rules that tell you how a particular business combination or divisive transaction is characterized, leaving you with the task of then applying the basic rules of subchapter k. Sounds simple? Well, as I'm sure you've already guessed, it's not. To navigate these rules for us we're fortunate to have Blake Rubin. ...

Private Equity

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

ERIC SLOAN: All right, we are going to get started again. As the amount of money that's invested with alternative asset managers has increased over the last 15 years or so, so too is the importance of understanding how those managers structure their investment vehicles. To help with that, our next panel will address topside planning for private equity and touch on hedge funds a little bit. We'll also talk about the various pass-through, cross border, ...

Interesting Partnership Transactions

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

STEPHEN ROSE: Making very real what we are talking about at this conference, our next panel will discuss a handful of recent and pending interesting transactions. To do just that, we have Linda Carlisle, Todd Keator, and Phil Wright. Linda is a member of Miller and Chevalier in Washington. Her practice focuses on advising corporations and flow-through entities such as partnerships, limited liability companies, and S Corps on both domestic and international ...

The Umbrellas of Subchapter K

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

CLIFFORD M. WARREN: I hope you all enjoyed the cookie break as much as I did. It's 3:30, which means it's time for "The Umbrellas of Subchapter K." The umbrella partnership is well known to those of you who have worked in the REIT area. But beginning with the ill-fated barnesandnoble.com, the umbrella structure moved into corporate America. Then, with the IPO of Lazard and the layering on of the tax receivable agreement, the umbrella partnership ...

Adjustments to the Basis of Partnership Assets (Sections 734, 743 and 754)

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

CLIFFORD WARREN: This next session is a very important one, a very difficult one. Put your seatbacks in the upright position, seatbelts on. In the event of a sudden loss of air pressure, oxygen masks will come down. Might not want to use them, but they'll be there. Picking up where we left off, we're going to move into some of the more complicated consequences of partnership distributions and transfers of interest. These rules are so important because ...

Sale, Exchange or Other Disposition of Partnership Interests; Partnership Distributions; Partnership Terminations

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

STEPHEN D. ROSE: All right, let's go ahead and get started. I was looking at my notes to see who I introduced next. And I realized, oh, wait, it's me. So for those who weren't here earlier in the day, I'm Stephen Rose. I'm one of the co-chairs of the program. And I'm going to do the last program of the day. And thank you very much for sticking around. So I'm going to cover a lot, quite frankly. I'm going to be covering partnership distributions, ...

The Basics of Basis (not including liabilities)

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

CLIFFORD WARREN: OK. Our next panel addresses basis issues. And to handle this incredibly important topic, we have two great speakers, Jim Tod and Benjamin Rippeon. Jim is a partner in the Passthroughs Group of KPMG's Washington National Tax office, and he specializes in alternative investment funds, as well as partnership business combinations and dispositions. Benjamin is a partner in the Washington D.C. office of Gibson Dunn. He has broad transactional ...

Oil and Gas Industry

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

CLIFFORD M. WARREN: It's come back, good. RYAN K. CARNEY: It's come back to you? Good. CLIFFORD M. WARREN: Well, thank you for that. It's now time for oil and gas. This is one of our specialty segments. And we were supposed to have Greg Matlock join Keith. But unfortunately or fortunately, Greg and his wife had a baby yesterday. KEVIN RICHARDS: Yes. CLIFFORD M. WARREN: So congratulations to them. And condolences to poor Keith, because he-- or ...

Allocation and Distribution Provisions

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

STEPHEN ROSE: Our next panel will focus on what many view as the very core of subchapter K, section 704(b), and what may well be the most important part of any partnership agreement-- the allocation and distribution provisions. To cover these important topics, we are lucky to have Todd Golub and Craig Gerson. Todd is a principal in the partnership transactional planning and economics group of Ernst & Young's national tax department, based in Chicago, ...

Hedge Funds

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

ERIC SLOAN: All right, moving right along, thank you, Lou. So we're going to move from private equity funds to hedge funds. In this session, we'll examine hedge fund structures, provide tax planning guidance for managers and investors, examine in more detail 704(c) methods applicable to hedge funds, and operational considerations. To guide us through this session, we really couldn't be more fortunate than to have Philippe Benedict. When I was in ...

Advanced Basis Issues: Impact of Liabilities

Transcripts  Transcripts    

Recorded on: Jun. 9, 2017

ERIC SLOAN: I'm going to pickup with "Advanced Basis Issues, the Impact of Partnership Liabilities." Partnership basis is just so important that we decided to have a second panel on it that studies the impact of liabilities on partner's bases, specifically doing a deep dive into the allocation of partnership liabilities among partners. To handle this, we're very fortunate to have Howard Abrams. Notwithstanding what the slide says, Howard is a professor ...

Basics of International Taxation 2017

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: Basics of International Taxation 2017

Released on: Aug. 4, 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: Jul. 20, 2017

JOHN L. HARRINGTON: Good morning, everyone. Welcome back to day two of PLI's Basics of International Taxation. As you may recall, yesterday we talked about the impact of the US tax rules on outbound investments. This morning we're going to focus on the US tax rules that apply to the tax concerns of persons investing inside the United States-- inbound investments. And then later on this afternoon, we'll turn to some things that affect both inbound ...

Cross-Border Services and Employment Tax Issues

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN HARRINGTON: So now we go from discussing transfers of property and services to discussing transfers of people. So we have our next panel is going to talk about the cross-border services and employment tax issues. So we have two panelists who will come up as soon as they get a chance. Apologies. There'll be a break following this one. While they're getting settled in, I'll introduce our two panelists. To my left is Anne Batter. She's a partner ...

Outbound Transfers of Intangible Assets and Treatment of Foreign Currency

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA CARLISLE: Well, we're back. And, as I said, we really are saving the best for last. This is a brand new panel this year where we are going to talk about outbound transfers of intangible assets, and the treatment of foreign currency. We are so very, very lucky to have Jose Murillo and Phil Wright tell us about these issues. Truly we're saving the best for last. Jose is a partner at EY where he heads EY's international tax services group focusing ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: Thank you. Welcome back, everyone. We just finished our first in-bound panel dealing with sort of what we call active business investments. And now our second panel for the morning will deal with the in-bound investments from a passive investment standpoint. And we have two excellent panelists here. To my immediate left is Bill Corcoran. He's a partner at Cooley LLP in Boston. And he represents leveraged buyout, venture capital, ...

International Tax Reporting and Dealing with Noncompliance

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA E. CARLISLE: Welcome back, everyone. I hope you had a good break and are ready for an afternoon of more excellent presentations. Our next panel is going to deal with international tax reporting and how the IRS deals with noncompliance. As we know, tax reporting by US persons with foreign income is required and is receiving a great amount of attention in recent years. Bob Temin and Josh Ungerman will tell us what forms will need to be filed and ...


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