eCourse
2016 Hot Topics in Tax Law: 385 Regulations, Goodwill, Personal Liability, Cancellation of Debt, and Family Limited Partnerships
Contains material from Jan 2017
2016 Hot Topics in Tax Law: 385 Regulations, Goodwill, Personal Liability, Cancellation of Debt, and Family Limited Partnerships
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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.
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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1.
Traps and Pitfalls of the New Section 385 Regulations (Jan 2017)
Bret Wells
0.75
0.00
0.00
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Session 1
—44 mins
Traps and Pitfalls of the New Section 385 Regulations (Jan 2017)
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.
Originally presented: Nov 2016 Taxation Conference
Bret Wells,
University of Houston Law Center - Houston, TX
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2.
Distinguishing and Planning around Individual Goodwill (Jan 2017)
Bruce A. Johnson, Kenton E. McDonald
1.00
0.00
0.00
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Session 2
—65 mins
Distinguishing and Planning around Individual Goodwill (Jan 2017)
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.
Originally presented: Nov 2016 Taxation Conference
Bruce A. Johnson,
Munroe, Park & Johnson, Inc. - San Antonio, TX
Kenton E. McDonald,
Branscomb | PC - Corpus Christi, TX
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3.
Personal Liability for Corporate Tax Assessments (Jan 2017)
James F. Martens
1.00
0.25
0.00
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Session 3
—62 mins
Personal Liability for Corporate Tax Assessments (Jan 2017)
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.
Originally presented: Nov 2016 Taxation Conference
James F. Martens,
Martens, Todd, Leonard, Taylor & Ahlrich - Austin, TX
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4.
Cancellation of Debt (Jan 2017)
Crawford Moorefield
0.75
0.00
0.00
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Session 4
—44 mins
Cancellation of Debt (Jan 2017)
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.
Originally presented: Nov 2016 Taxation Conference
Crawford Moorefield,
Strasburger & Price, LLP - Houston, TX