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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 ...

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 ...

Overview of U.S. International Tax System

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: For our first panel, like I said, this is intended to be kind of an overview of the US international tax rules. And I'll just start off with the two basic general rules. The US persons are subject to tax on their worldwide income, US tax and worldwide income. Non-US persons are typically taxed only on their US source income. Now, if that was all to these rules, you wouldn't be here for two days. So there's obviously a lot of sort ...

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 ...

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 ...

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 ...

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, ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA CARLISLE: Now that we have a basic understanding of the international tax rules, or at least how they're intended to operate, we're going to get to the real nitty gritty of how they do operate. And we have five more panels today that will go through the specifics of how US taxes outbound and inbound transactions. Now tomorrow, we'll deal with inbound transactions, and investments, and transfer pricing, and cross-border, and the diseases we were ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA E. CARLISLE: Well, welcome back. Our next panel is going to deal with the tax concerns of US persons investing or operating outside the United States through more passive investments. Remember, our last panel talked about the active businesses. Now, we're going to talk about passive-- lending, licensing, portfolio investments. And to lead us in this discussion, I couldn't be more pleased to have these two terrific people-- Ethan Atticks and ...

International Tax Aspects of Tax Reform

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: Thanks. That was the first reward for staying all the way through the end of the conference. The second reward is getting to hear our two distinguished panelists talk about the international aspects of tax reform. And this is a very hot topic. It's hard to make a lot of sense of it. So they're both going to do their best at doing that. In this case, we're fortunate to have, at my far left, Janice Mays. Janice is the managing director ...

Qualified Small Business Stock Trends in Venture Financings and Mergers and Acquisitions

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

Recorded on: Jul. 27, 2017

Taken from the briefing Qualified Small Business Stock Trends in Venture Financings and Mergers and Acquisitions recorded July, 2017 in New York. The “qualified small business stock” (QSBS) provisions of the Internal Revenue Code allow taxpayers to exclude a specified percentage of gain recognized on the sale of eligible QSBS held for over five years, which exclusion, for shares issued on or after September 28, 2010, may be 100% (subject ...

Qualified Small Business Stock Trends in Venture Financings and Mergers and Acquisitions

Transcripts  Transcripts    

Recorded on: Aug. 3, 2017

AMY TAUB: Hello. My name is Amy Taub and I am a program attorney with PLI, a nonprofit learning organization. I would like to welcome you to today's briefing, Qualified Small Business Doctrines and Venture Financings in Mergers and Acquisitions. Before we begin, I have some adminirative announcements. This briefing will be one hour in length. Please feel free to send questions at any time during the briefing. Please remember that you have access to ...

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 ...

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 ...

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 ...

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 ...

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 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 ...

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 ...

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 ...

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

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

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, ...


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