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Economic Substance Codification Update: Impact on Audits and Transaction Planning

Understand the foundational principles of judicial doctrines relevant to taxation, including the economic substance doctrine, and its evolution over time.

As seen in cases such as Liberty Global and Perrigo, the IRS is more frequently asserting arguments based on the economic substance doctrine and related penalties. This webinar will outline the evolution of this doctrine, the history of the IRS' position, and the current cases. This webinar will address this doctrine manifesting in audits, penalty considerations, and how practitioners should evaluate economic substance arguments at the outset of transactions.

98 minutes
Certificate of Completion
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Why Lorman?

Over 37 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

Overview

  • Background on Judicial Principles
  • History of IRS Position
  • Ongoing Controversies

Practical Considerations

  • Audit Practices and Strict Liability Penalties
  • Planning Considerations
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Why Lorman?

Over 37 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

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Maine, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on May 15, 2024.

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

  • AK CLE 1.5
     
  • Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
     
  • 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 1.5
     
  • This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. 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, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • 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 1.5
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.5 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.
     
  • IN CLE 1.7
     
  • This program has been approved by the Indiana Commission on Continuing Legal Education. Participating attorneys are eligible to receive up to 1.7 hours of Distance Education credit.
     
  • MO CLE 2.0
     
  • This course qualifies for self-study CLE credit in Missouri.
     
  • ND CLE 1.5
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.5 hours of CLE credit.
     
  • NH MCLE 1.6
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 98 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.
     
  • NM CLE 1.6
     
  • This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.6 hours of credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • NY CLE 1.5 including Areas of Professional Practice 1.5
     
  • This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 1.5 credit hours in the area(s) of Areas of Professional Practice for 1.50 hours. Each hour may be counted only as satisfying one category of credit. Duplicate credit for the same hour of instruction is not permitted. This course qualifies for both established and newly admitted attorneys. Lorman Business Center, LLC. has a financial hardship guideline. Please contact customer service at 1.866.352.9539 for instructions on how to apply.
     
  • 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 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • VT CLE 1.5
     
  • This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
     
  • WI CLE 1.5
     
  • This program qualifies for 1.5 hour(s) of ondemand CLE through the WI Board of Bar Examiners.
     
  • WV MCLE 2.0
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 2.0 MCLE hours.
     
The CLE Code is ONLY a requirement when applying for CLE Credit in New York. Other states do not need to supply the CLE Code to apply for CLE credit.

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

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

MP3 Download

  • AK CLE 1.5
     
  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • MO CLE 2.0
     
  • NJ CLE 2.0
     
  • NM CLE 1.6
     
  • NY CLE 2.0 including Areas of Professional Practice 2
     
  • VT CLE 1.5
     
  • 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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Why Lorman?

Over 37 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

Samuel Lapin

Samuel Lapin

Miller & Chevalier Chartered

  • Counsel in the Tax Department at Miller & Chevalier Chartered
  • Practice concentrates on tax controversy and litigation matters
  • Experience in representing clients during IRS audits and before the IRS Independent Office of Appeals on a variety of issues, including the R&D credit, partnership basis adjustments, management fee waivers, charitable contributions, and collection and penalty issues
  • Assists clients with international tax planning and tax policy matters
  • Active member of the ABA Tax Section and the DC Bar Tax Community and former Law Clerk to Judge Cary Douglas Pugh on the U.S. Tax Court
  • Recognized by The Best Lawyers in America for Litigation and Controversy - Tax (Ones to Watch) and Tax Law (Ones to Watch)
  • Conducts regular seminars and workshops on administrative practice and procedure and tax controversy issues
  • J.D. degree, cum laude, Temple University Beasley School of Law; B.A. degree, University of Pittsburgh
  • Can be contacted at 202-626-5807 or [email protected]
Caroline Reaves

Caroline Reaves

Miller & Chevalier Chartered

  • Counsel at Miller & Chevalier Chartered
  • Practice covers a broad range of federal income tax matters with a focus on cross-border transactional issues and business activities
  • Represents domestic and international corporations, partnerships, individuals, and S corporations in the energy, technology, consumer product, healthcare, and industrial sectors
  • Named “One to Watch” in Litigation & Controversy and Tax Law by The Best Lawyers in America, 2024
  • Frequent speaker at American Bar Association (ABA), International Fiscal Association, Federal Bar Association, and Tax Executives Institute (TEI) events and presents on a broad range of topics, including transfer pricing, Pillar 1 and Pillar 2, and common-law doctrines
  • J.D. degree, with honors, The George Washington University; B.A. degree, Colby College
  • Can be contacted at 202-626-5939 or [email protected]
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Why Lorman?

Over 37 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

All of your training, right here at Lorman.

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  • State Specific Credit Tracker
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Questions? Call 877-296-2169 to speak with a real person.

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Product ID: 411159
Published 2024
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