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Live Webinar

100-minute live streaming program
  • March 13
  • 1:00 - 2:40 pm EST

Tax Planning for Disregarded Entities: Issues, Risks, and Opportunities

March 13

Gain a better understanding of the opportunities and pitfalls of using disregarded entities for a wide range of tax planning purposes.

The use of limited liability companies has proliferated both in the U.S. and elsewhere. The tax treatment of such entities by U.S. and foreign tax agencies has become increasingly complicated, and is often counter intuitive. This topic will help you identify the appropriate classification of entities for U.S. and foreign tax purposes; determine the correct reporting requirements for such entities; understand the role of LLCs in structuring M and A transaction on a tax-free basis; and understand how foreign tax agencies classify U.S. LLCs.

Learning Objectives

- You will be able to explain the difference between the default classification rules for domestic and foreign entities.

- You will be able to describe how to structure tax-free domestic M and A transactions using LLCs.

- You will be able to discuss the advantages of using LLCs rather than corporate subsidiaries and why doing so avoids the complications that arise with consolidated tax return groups.

- You will be able to identify the appropriate tax reporting forms for foreign owned LLCs.

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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Classification Issues
  • U.S. Single Member Limited Liability Companies
    • Classification for Corporate Law Purposes
    • Classification for U.S. Income Tax Purposes Disregarded Entity vs. Corporation (C and S)
    • Classification for Employment Tax Purposes
    • Classification of U.S. LLCs for Foreign Tax Purposes
    • Reporting Requirements for Foreign Owned LLCs
  • Foreign Entities
    • Default Classification for Income Tax Purposes
    • Elective Classification for Income Tax Purposes
Consolidated Tax Return Issues
  • Corporate Subsidiaries
  • LLC Subsidiaries
Mergers and Acquisitions
  • U.S. M and A Transaction
  • Foreign M and A Transaction
    • Partnership Transactions
    • LLC Mergers
    • LLC Separations
Hybrid Entities and Withholding Tax Issues
  • Domestic Hybrids
  • Foreign Hybrids
Estate and Gift Tax and LLCs
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

Live Webinar Registration

  • AIPB 2.0
     
  • This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • AL CLE 1.7
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.7 hours credit.
     
  • AR CLE 1.75
     
  • This course has been approved for 1.75 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CO CLE 2.0
     
  • This program may qualify for 2.0 credit hours through the Colorado Supreme Court Board of Continuing Legal and Judicial Education through reciprocity. This course is accredited in other jurisdictions such as New Jersey. To receive CLE credit for this program, a home study affidavit must be submitted to the Supreme Court Board of Continuing Legal and Judicial Education.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • GA CLE 1.7
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.7 CLE hours.
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • MS CLE 1.7
     
  • This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.7 credit hours.
     
  • MT CLE 1.75
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.75 CLE credits.
     
  • NH MCLE 1.7
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 100 Minutes.
     
  • NJ CLE 2.0
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 2.0 hours of total CLE credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 2.0
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 2.0 hours of CLE credit.
     
  • TN CLE 1.67
     
  • This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.67 hours of credit.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of CLE credit.
     
  • WA CLE 1.75
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.75 hours of Law & Legal Procedure credit.
     
  • WI CLE 2.0
     
  • This program has been approved by the Board of Bar Examiners for 2.0 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 2.0
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 2.0 MCLE hours.
     
  • CPE 2.0 including Taxes 2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.0 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.0 hours. Prerequisite: basic knowledge of general accounting. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, Inc. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Taxation for 2.0 hours.
     
  • Lorman Business Center, Inc. has registered with the Texas State Board of Public Accountancy as a CPE Sponsor. This registration does not constitute an endorsement by the Board as to the quality of our CPE Program. This program qualifies for 2.0 hours of continuing professional education.
     

Who should attend?

This live webinar is designed for accountants, CFOs, controllers, accounts payable professionals, tax managers, presidents, vice presidents, bookkeepers, and tax attorneys.

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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Charles S. Kolstad

Charles S. Kolstad

Mitchell Silberberg & Knupp LLP

  • Tax partner in the Los Angeles office of Mitchell Silberberg & Knupp, LLP
  • Advises clients, accountants, and business managers throughout the U.S. on the income tax issues and reporting requirements that arise when individuals or companies conduct business outside of the U.S.
  • Advises U.S. clients on structuring foreign business activities with a view to minimizing their global effective tax rate on foreign income
  • Advised nonresident aliens planning on moving to the U.S. on the U.S. tax reporting requirements that apply once they become a U.S. tax resident, pre-immigration planning to step-up basis of assets, eliminate U.S. tax on previously earned income, etc.
  • Frequent speaker on income tax and international reporting requirements, and regularly prepares tax bulletins on topical issues
  • During his career, he has been a tax partner at both Coopers & Lybrand LLP and Ernst & Young LLP
  • J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 401066
Published 2018
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