Hot Topics in Taxation 2015

Session 1: Eggshell Audits: Handling IRS Examinations When There Are Potential Criminal Issues - Review issues that arise during IRS civil audits of individuals and businesses in which the revenue agent is unaware of material errors and possible fraudulent conduct with respect to the returns. Topics include: the role of IRS Fraud Technical Advisors; the client decision between cooperation and remaining silent to avoid self-incrimination; the use of Kovel accountants; the government’s use of administrative summonses; the problems presented by large corporate investigations and parallel proceedings; and the signs that a case may have been referred for criminal investigation.
 
Session 2: Investment in United States Real Property by Non-U.S. Investors - Many foreign individuals, pension plans and governments are looking at investments in U.S. real estate. Taxation is a major part of any investment decision, and if such an investment is properly structured, the foreign investor could pay little or no U.S. tax. Learn how to structure foreign investment in U.S. real estate to minimize U.S. taxation and withholding.
 
Session 3: Partnership Equity Compensation—Crescent Holdings and Related Issues - Review the implications of the failure to make a Section 83(b) election with respect to an unvested compensatory partnership interest and how such implications may differ depending upon whether the partnership interest is a capital interest or a profits interest.
 
Session 4: The Final Tangible Property Regulations: Practical Considerations in the Post-Implementation Period - The final tangible property regulations became effective for tax years beginning in 2014 and required most business taxpayers to file one or more changes in method of accounting to implement the new rules for acquisitions costs, material and supplies, de minimis expenses, repairs vs. improvements, and property dispositions. Many businesses implemented these regulations in some fashion, but due to the comprehensive impact of the rules and the heavy reliance on facts and circumstances, many businesses have more to do to evaluate their tax accounting methods for tangible property, including offices buildings, retail properties, manufacturing facilities and equipment, and other capital assets. This session will discuss the practical steps that businesses are taking to consider whether additional accounting method changes or the election of safe harbors could better optimize the tax accounting for tangible property costs going forward.
 
Session 5: Circular 230 Update - Consider the recent court decisions and regulatory changes that have reshaped Circular 230, including implications for practitioners.

Includes: Audio Paper Slides