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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 ...

Basics of International Taxation 2016 -- Overview of U.S. International Tax System

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

From the program: Basics of International Taxation 2016

Recorded on: Jul. 21, 2016

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Lecture Topics [01:05:25] Upon the successful completion of this program, the participant will be able to: Understand the general rules regarding U.S. income taxation of worldwide income earned by both U.S. and non-U.S. persons. Recognize the U.S. federal income tax treatment of U.S. persons with regard to foreign ...

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) ...

Cannabis Law: A New Frontier in California and Beyond

On-Demand Web Briefing  On-Demand One-Hour Briefing    

From the program: Cannabis Law: A New Frontier in California and Beyond

Released on: Jan. 14, 2017

Taken from the briefing Cannabis Law:  A New Frontier in California and Beyond recorded January 2017 in New York. With a ballot initiative over 20 years ago, the citizens of California passed Proposition 215, the first medical cannabis law in the country. Despite this, California failed to pass implementing legislation that would provide clear and specific regulatory guidance for those wishing to engage lawfully in medical cannabis ...

Cannabis Law: A New Frontier in California and Beyond

Transcripts  Transcripts    

Recorded on: Jan. 14, 2017

AMY: It is now my pleasure to turn this brifing over to Larry Rosen. LARRY ROSEN: Thank you, Amy. I appreciate the introduction. And I'm going to try to introduce the other two speakers this morning who are far more knowledgeable than I about cannabis law, have been doing this for many more years than I have been. As I said, or as Amy said, I'm a technology attorney and business attorney. And so my area of interest in this field is to see that, ...

Foreign Account Tax Compliance Act 2017: What Financial Institutions and Withholding Agents Need to Know Now

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

Recorded on: Mar. 7, 2017

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Lecture Topics [01:07:54] Upon the successful completion of this program, the participant will be able to: Recall the implementation and present status of the Foreign Account Tax Compliance Act (FATCA). Recognize key provisions contained in the final and temporary regulations issued under Internal Revenue Code (IRC) §§1471-1474 ...

Foreign Account Tax Compliance Act 2017: What Financial Institutions and Withholding Agents Need to Know Now

Transcripts  Transcripts    

Recorded on: Mar. 9, 2017

AMY TAUB: Hello. My name is Amy Taub. And I'm a program attorney with PLI, a nonprofit learning organization dedicated to keeping attorneys and other professionals at the forefront of knowledge and expertise, as well as preparing them to fulfill their pro bono responsibilities. I'd like to welcome you to today's briefing; "Foreign Account Tax Compliance Act 2017, What Financial Institutions and Withholding Agents Need to Know Now." Before we begin, ...

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

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 ...

International Estate & Tax Planning 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: International Estate & Tax Planning 2017

Released on: May. 26, 2017

As individuals and business taxpayers increasingly globalize their personal and commercial activity, they expose themselves to greater legal and tax obligations.  Legal advisors must consult their clients with a complete understanding of applicable tax regimes and multijurisdictional issues.  Whether their clients are United States persons with assets or beneficiaries overseas, non-U.S. persons with ties to the U.S. or business entities ...

U.S. Immigration and Expatriation Issues for International Private Clients

Transcripts  Transcripts    

Recorded on: May. 23, 2017

ROBERT DUMONT: Welcome back, everyone. Now that you've partially digested your lunch and fully digested this morning's program on disclosure compliance and enforcement, we're going to turn to planning-- estate planning and tax planning-- for international private clients. As well as being a generally sensitive guy, Steve Trow is a very tax-sensitive immigration lawyer. He has over 30 years of experience in US immigration and citizenship law and is ...

Developments in International Information Reporting for Private Clients

Transcripts  Transcripts    

Recorded on: May. 23, 2017

ROBERT DUMONT: It's a gray Monday morning. What should we start with? International informational disclosure forms. FATCA, CRS, the juicy bits. That's what we're going to start with. And I shouldn't make fun of it because it's not funny stuff. Often in cases where there is no substantive tax liability, there can be penalties imposed if you get the informational reporting incorrect. So it's very, very important. Karen Brodsky is a partner in the accounting ...

U.S. Family Office Structures and Operations for Global Families

Transcripts  Transcripts    

Recorded on: May. 23, 2017

THOMAS J. HANDLER: I'm going to start by just talking a little bit about exactly what these enterprises are and how they function. And I think, part of the reason that this area is not well-documented is that it's still a relatively nascent industry. In 1988, there was very little written about legal structures, liabilities, tax estate, risk management, asset protection-- almost nonexistent, as it related to family offices. Although there have been ...

Foreign Trust Tax Planning: The Difficult Questions

Transcripts  Transcripts    

Recorded on: May. 23, 2017

DEAN BERRY: Thank you very much. And I'm going to turn the program over to my distinguished panel here. If you've attended this session in the past, you know that we usually spend a lot of time talking about foreign trusts, US connection, typically US tax issues. And what the panel is going to do today is look at some of the hard and interesting. So it's not just going to be a long summary of these are the rules, but a lot of those will come out in ...

Advising Nonprofit Organizations 2017

On-Demand Web Programs  On-Demand Web Programs    

From the program: Advising Nonprofit Organizations 2017

Released on: May. 24, 2017

Nonprofits are under heightened scrutiny to account for their management and fiduciary practices, and managing a nonprofit has become increasingly complex.  This program is designed to examine federal and state laws and regulations affecting nonprofits, as well as new challenges and practical solutions for overcoming those challenges. You will learn: Best practices for good governance How to handle ethical issues that can arise ...

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 ...

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 ...

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 ...

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 ...

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 ...

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 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 ...

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 ...

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. ...

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 ...

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, ...


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