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Live Webinar

90-minute live streaming program
  • December 18
  • 1:00 - 2:30 pm EST

Tax Considerations for Commercial Loan Documents

December 18

Understand available options and evaluate the tax consequences related to different aspects of commercial loan documents.

In the Post-TCJA and CARES Act era, commercial loans have faced sudden and uncertain pressures. Loan document drafting, restructuring, and forgiveness can provide opportunities for borrowers and lenders. However, they are often accompanied by significant tax consequences that can have long-term financial effects on borrower, lenders, and investors.

This material will help you understand available options and evaluate the tax consequences related to different aspects of commercial loan documents. This will help you evaluate the tax consequences loan modifications for borrowers, lenders and investors.

Learning Objectives

  • You will be able to describe tax implications of the CARES Act and the TCJA on commercial loan documents.
  • You will be able to discuss limitation on the deductibility of business interest expense under new IRC Section 163(j).
  • You will be able to explain why pledges and guarantees by foreign subsidiaries are an important consideration.
  • You will be able to identify several ways in which a loan may be restructured to take advantage of the new rules after tax reform and the CARES Act.

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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

Limitation on the Deductibility of Business Interest Expense Under New IRC Section 163(j)

Section 163(j) Limitations for Partnerships and S Corporations

Exceptions to 163(j) Limitations

TCJA Implications for Cross-Border Transactions

Changes to Tax Rates Under the TCJA

Impact on Permitted Tax Distributions Provisions in Loans to Pass-Through Borrowers

Pledges and Guarantees by Foreign Subsidiaries

The Pre-TCJA Taxation of Offshore Earnings and Section 956

Taxation of Offshore Earnings Under the TCJA

The Section 956 Regulations

Scenarios Where Section 956 Is Still Relevant

The New Limitations EBITDA/EBIT on Interest Deductions

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More Program Information

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

Live Webinar Registration

  • CPE 1.8 including Taxes 1.8
     
  • 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: 1.8 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 1.8 hours. Prerequisite: basic knowledge of the banking industry. 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.
     

Who should attend?

This live webinar is designed for presidents, vice presidents, branch managers, business owners and managers, loan officers, loan department personnel, accountants, mortgage brokers, underwriters, real estate professionals, and appraisers.

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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

Cliff A. Capdevielle, Esq.

Cliff A. Capdevielle, Esq.

Moskowitz, LLP

  • Managing attorney of Moskowitz, LLP
  • Practice leader of the Tax Compliance Group and a member of the firm’s Professional Services and Construction Services Groups
  • More than 25 years of legal, accounting and business advisory experience working with corporate, individual, and partnership tax entities
  • Background also includes a stint with Deloitte
  • Experience has made him an important resource for closely held companies and high-net-worth individuals
  • Expertise has allowed him to successfully represent many clients before several federal, state, and local taxing authorities, has granted him the opportunity to contribute to many industry publications
  • Can be contacted at 415-394-7200, [email protected] and moskowitzllp.com
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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.

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Product ID: 406875
Published 2020
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