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OnDemand Webinar

Economic Substance Codification Update: Impact on Audits and Transaction Planning

This OnDemand Webinar provides an update on recent IRS guidance and cases involving the codification of economic substance. Many of these cases have substantially refined the landscape. Because economic substance permeates all tax planning and audit issues, it is important for everyone who deals with tax issues to keep up with the developments and arguments that impact how the IRS and courts view economic substance and what taxpayers are expected to provide to defend the treatment of transactions.

Learning Objectives:

  • You will be able to define "Safe Harbors."
  • You will be able to discuss the Two Prong Test.
  • You will be able to explain Notice 2010-62.
  • You will be able to review first and second Economic Substance Directives.

Runtime: 94 minutes
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Why Lorman?

Over 32 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

When Does the Economic Substance Doctrine Apply?

  • In General
  • Congressional Plan or Purpose
  • Certain Credits
  • "Safe Harbors"
  • Disaggregation of Transactions

The Two Prong Test

  • The Objective Component
  • The Subjective Component

The Individual Exception

Strict Liability Penalties

Notice 2010-62

First Economic Substance Directive

Second Economic Substance Directive

Other Practice and Procedure Issues

Selected Recent Economic Substance Cases

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More Program Information

Why Lorman?

Over 32 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 February 22, 2013.

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

No Credit Available

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

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Why Lorman?

Over 32 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

Matthew D. Lerner

Matthew D. Lerner – Moderator

Sidley Austin LLP

  • Partner in the Washington-based law firm of Steptoe & Johnson LLP
  • Member of the Business Solutions and Litigation Departments
  • Practice focuses on representing clients in all aspects of the tax controversy process, from pre-audit advice about file organization and privilege protection, to representation during IRS audits, appeals, and litigation in Federal Courts
  • Key clients include corporations and high net worth individuals with complex tax issues covering a broad range of substantive areas
  • Recently handled matters for clients involving the Economic Substance Doctrine, repair and rehabilitation expenses; classification of assets for depreciation purposes; losses from trading in securities and derivatives; debt versus equity classification; corporate spin-offs and liquidations; miscellaneous corporate fees and expenses; international intercorporate transactions and the foreign tax credit; tax accounting method questions; and valuation issues
  • Recommended, The Best Lawyers in America 2013, Tax Litigation and Controversy; The Best Lawyers of America 2012, Tax Law; Washington, DC Super Lawyers 2012; Legal 500 US 2012, Tax: Controversy and Chambers USA 2012, America’s Leading Business Lawyers, Tax Controversy: Nationwide
  • •J.D. degree, Harvard Law School; A.B. degree in economics, Amherst College, Nelson Prize in Economics Fellow, American College of Tax Counsel
  • Can be contacted at [email protected] or 202-429-8024
Gregory N. Kidder

Gregory N. Kidder

Steptoe & Johnson LLP

  • Partner in the Washington office of Steptoe & Johnson LLP, where he is a member of the firm’s Business Solutions Department
  • Practice focuses on federal income taxation issues, with particular emphasis on the taxation of corporate entities and cross-border transactions
  • Advises clients on structuring corporate transactions, including mergers, acquisitions, and spin-off transactions for large public corporations, as well as closely held businesses
  • Advises clients on international issues, including deferral, foreign tax credits, and tax treaty matters
  • Assists clients in tax controversy matters, including all stages of the Internal Revenue Service administrative process and in litigation
  • Extensive experience negotiating with field agents, appeals officers and district counsel in settling significant audit issues
  • J.D. degree, Harvard Law School; A.B. degree, Duke University
  • Can be contacted at [email protected] or 202-429-6755
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Why Lorman?

Over 32 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!

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  • State Specific Credit Tracker
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* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

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Product ID: 389468
Published 2013
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