Session 1: Traps and Pitfalls of the New Section 385 Regulations - The Section 385 regulations are a sea-change event that will have profound impact given the three-year presumptions contained in the regulations and that they broadly apply to many deleveraging transactions and create a presumption of linkage. Explore the impact of Section 385 on debt pushdown strategies, potential workarounds to those impacts, scope limitations of the Section 385 regulations that define “tainted” debt versus “clean” debt, and the collateral damage of the Section 385 regulations to unanticipated situations.
Session 2: Distinguishing and Planning around Individual Goodwill - Practitioners and appraisers once dismissed distinguishing and planning around "individual goodwill" as far from serious. Now the practice is increasingly accepted and is in widespread use in ways which are, in fact, only a step or two away from negligence, if not fraud. Review these concepts and their limits, especially as they relate to structuring and restructuring around corporate lockup of built-in gains.
Session 3: Personal Liability for Corporate Tax Assessments - It’s your client’s worst nightmare. After serving as an officer, a director, or in some cases, an employee of a failed business, there’s a knock on the door. It’s from a sheriff serving a lawsuit alleging the client is personally liable for his or her employer's unpaid Texas taxes. Learn the laws that impose personal liability and how best to defend against it.
Session 4: Cancellation of Debt - Explore how the downturn in the energy industry has made COD issues of more frequent concern, as have issues arising in connection with restructuring of debt obligations of partnerships and LLCs.
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Total Credit Hours:
3.50 | 0.25 ethics
TX MCLE credit expires: