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OnDemand Course

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.

Learning Objectives

  • You will be able to differentiate between the A, B, and C reorganization types.
  • You will be able to identify US Tax Classification Issues
  • You will be able to recognize Foreign Classification Issues.
  • You will be able to identify reporting and Tax issues.

Runtime: 102 minutes
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Why Lorman?

Over 33 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 33 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 Course

This course was last revised on February 13, 2019.

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

  • CPE/NASBA - QAS Self Study 2.5 including Taxes 2.5
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study 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: 2.5 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.5 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement 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.
     
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Why Lorman?

Over 33 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

Withers Bergman LLP

  • Tax partner Withers Bergman LLP, a leading international private capital law firm, specializing in international tax matters
  • Focuses his practice on international tax, corporate, and partnership matters; he assists clients in tax and corporate planning relating to the acquisition, disposition and restructuring of businesses, corporations and partnerships both domestically and internationally
  • Frequently advises foreign individuals moving to the U.S. on pre-immigration, income, gift and estate tax planning opportunities; he also focuses his practice on the cannabis industry/cannabusiness, crypto assets and block chain technology, and tax issues related to initial coin offerings (ICOs)
  • Has advised over 200 clients with unreported foreign 1nancial accounts, foreign trusts, and other foreign investments, on the 1ling of FBARs and other information returns, and whether participating in the IRS’s various offshore voluntary disclosure programs is appropriate
  • Written and lectured on the extensive information reporting requirements for U.S. taxpayers with international business operations
  • During his career he’s been at Mitchell Silberberg & Knupp LLP and Venable LLP and was a tax partner at both Coopers & Lybrand and Ernst & Young
  • 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 33 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.

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
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  • Course Manuals
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  • Executive Reports
  • White Papers and Articles
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  • State Specific Credit Tracker
  • Members Only Newsletter
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* For audio recordings you only pay shipping

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Product ID: 405728
Published 2019
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