1-Hour Program

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Overview

Archaic prohibitions on tax deductions combined with arcane interpretations of these prohibitions by the IRS, courts, and taxpayers with respect to facts unique to each taxpayer have created an overall atmosphere of fear and uncertainty in U.S. tax planning and reporting within the cannabis industry.  Jonathan de Jong, Douglas Sayuk, and James Stanley from Alvarez & Marsal Taxand, LLC will:

 

  • Walk through the history of Section 280E and its current state;
  • Highlight some of the key markers that can lead to success or failure in optimizing tax deductibility within the various sectors of this diverse industry (CHAMP versus subsequent cases/rulings);
  • Discuss the relative applications and merits of the methods for ensuring that participants in this industry are not taxed unconstitutionally on their gross incomes (263A versus stricter options; manufacturer versus retailer); and
  • Review the weight of U.S. international tax law principles with respect to operations of foreign subsidiaries.

 

Program Level:  Overview

Intended Audience:  In-house counsel, outside attorneys, accountants, and other finance professionals involved in the cannabis industry

Prerequisites:  None

Advanced Preparation:  None

 

Credit Details