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

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.

Runtime: 102 minutes
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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

OnDemand Webinar

This course was last revised on March 29, 2018.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • GA CLE 1.7
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

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 accountants, business managers and clients throughout the US on the income tax issues and reporting requirements that arise when individuals or companies conduct business outside of the US
  • Assist clients with the offshore migration of US developed Intellectual Property
  • Advises nonresident aliens planning on moving to the US on the US tax reporting requirements that apply once they become a US tax resident, pre-immigration planning to step-up basis of assets, eliminate US tax on previously earned income, etc.
  • Represented some 160 clients with unreported foreign bank accounts, foreign trusts, 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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