eCourse
Hot Topics in Taxation 2015
Contains material from Jan 2016
Not my area yet was interesting
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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
Preview Sessions
Show session details
Larry A. Campagna
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Session 1
—58 mins
Eggshell Audits: Handling IRS Examinations When There Are Potential Criminal Issues (Jan 2016)
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.
Originally presented: Dec 2015 Taxation Conference
Larry A. Campagna,
Chamberlain, Hrdlicka, White, Williams & Aughtry - Houston, TX
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Richard M. Lipton
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Session 2
—58 mins
Investment in United States Real Property by Non-U.S. Investors (Jan 2016)
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.
Originally presented: Dec 2015 Taxation Conference
Richard M. Lipton,
Baker & McKenzie - Chicago, IL
Show session details
Bahar A. Schippel
Session 3
—51 mins
Partnership Equity Compensation—Crescent Holdings and Related Issues (Jan 2016)
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.
Originally presented: Dec 2015 Taxation Conference
Bahar A. Schippel,
Snell & Wilmer LLP - Phoenix, AZ
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Carol Conjura
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Session 4
—58 mins
The Final Tangible Property Regulations: Practical Considerations in the Post-Implementation Period (Jan 2016)
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.
Originally presented: Dec 2015 Taxation Conference
Carol Conjura,
KPMG LLP - Washington, DC
Show session details
Dennis B. Drapkin
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Session 5
—55 mins
Circular 230 Update (Jan 2016)
Consider the recent court decisions and regulatory changes that have reshaped Circular 230, including implications for practitioners.
Originally presented: Dec 2015 Taxation Conference
Dennis B. Drapkin,
Southern Methodist University Dedman School of Law - Dallas, TX