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.
Learning Objectives
- You will be able to understand the foundational principles of judicial doctrines relevant to taxation, including the economic substance doctrine, and its evolution over time.
- You will be able to examine the historical development of the IRS’s stance on the economic substance doctrine and its application in taxation cases.
- You will be able to analyze ongoing controversies surrounding the economic substance doctrine and related penalties.
- You will be able to explore audit practices about the economic substance doctrine and strict liability penalties, focusing on how these principles are applied in IRS audits.
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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
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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
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).
- AK CLE 1.5
- Alaska attorneys may receive 1.5 hours of continuing legal education, including hours of ethics credit 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 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, 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).
- HI CLE 1.5
- This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 VCLE 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 program has been approved by the Missouri Bar for 2.0 hours of CLE.
- ND CLE 1.5
- This program has been reviewed by the North Dakota Commission for Continuing Legal Education and approved for 1.5 hours of CLE credit.
- 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.
- 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 2.0 including Areas of Professional Practice 2
- This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 2.0 credit hours in the area(s) of Areas of Professional Practice for 2.00 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.
- OH CLE 1.75
- This course has been approved by the Ohio Supreme Court Commission on Continuing Legal Education for 1.75 CLE credit hours.
Please note: In order to receive OH CLE credit for this audio conference you MUST use the streaming option and enable and complete the required progress checks. This course is considered Self-Study. No more than twelve (12) hours of self-study CLE credit for any biennial reporting period may be earned by an Attorney or Judge under Regulation 409.2.
- PA CLE 1.5
- This 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.
- VA CLE 1.5
- This program has been approved by the Virginia Mandatory Continuing Legal Education Board for 1.5 CLE credit hours.
- 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.
- 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.
Enrolled Agents 2.0
- In accordance with the standards set forth in Circular 230 section 10.6, CE credits have been granted based on a 50-minute hour. This program qualifies for 2.0 Continuing Education Credit(s) for enrolled agents.
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: www.nasbaregistry.org. 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: . 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.
OnDemand Course
This course was last revised on February 22, 2013.
Call 1-866-352-9540 for further credit information.
No Credit AvailableThis program does NOT qualify, nor meet the National Standard for NASBA accreditation.
Who should attend?
This live webinar is designed for accountants, CPAs, controllers, attorneys, presidents, vice presidents, CFOs, tax managers, tax preparers, finance directors, bookkeepers and enrolled agents.
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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
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
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.
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