The IRS has reversed its 2006 position on the tax free treatment of section 304 cross border stock for property exchanges, and now these transactions may be subject to tax.
Corporate tax reform packages have been issued by all the presidential candidates and corporate tax change will take place. Information reporting has increased dramatically and we still don't know exactly what constitutes "organization action" for purposes of reporting on Form 8937. This OnDemand Webinar will help professionals charged with the responsibility to steer their companies on the not so straight and narrow path. The program will also detail the most significant set of sweeping information reporting changes in a decade and provide best practices for tax managers and directors so that they can meet the future needs of their companies. Finally, you cannot plan for the future if you are not fully aware of what the future holds. This OnDemand Webinar will include a detailed discussion of the most likely changes that all corporations will face under the various corporate tax reform proposals.
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Why Lorman?
Over 37 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
Tax Free Reorganization Update
- Continuity of Interest Rules
- Hot Stock Rules and Section 355
- Losses, Expenses, and Interest With Respect to Transactions Between Related Taxpayers
Exchange of Stock for Foreign Assets
- T.D. 9250
- Notice 2012-15
- Gain Recognition Agreements
Section 332(h) Elections
- PLR 2012206010
- Due Diligence Matters
- State Developments
Accumulated Earnings
- Issue Raised More Frequently on IRS Exams
- Build Your Case
Executive Compensation
- Section 409A
- Stay-On Pay
Information Reporting
- FATCA
- Forms 1099
- Schedule UTP
- Form 8937
- Forms 3921 and 3922
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More Program Information
Why Lorman?
Over 37 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 Course
This course was last revised on May 15, 2012.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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More Program Information
Why Lorman?
Over 37 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
Mark Heroux – Moderator
Bakertilly
- Principal in the Tax Services Group at Baker Tilly Virchow Krause, LLP
- More than 20 years of IRS tax litigation, technical and program management experience
- Concentrates on IRS procedures, controversy and dispute resolution
- Leads and provides tax and business advisory services to middle-market and large companies, and high net worth individuals
- Advises clients on state and federal corporate and individual taxation with an emphasis on risk management, FIN 48 planning and compliance, FAS 109 determinations, and other reporting and disclosure issues
- While at the IRS, he served as a special assistant United States attorney litigating tax and collection issues in the U.S. Bankruptcy Court, negotiating advance pricing agreements with the IRS National Office and U.S. Competent Authority, and litigating small and large tax cases in the U.S. Tax and District Courts; and as special tax counsel and special assistant attorney general for the government of Guam, litigating tax cases, white-collar crime cases, and advising the government of Guam on tax policy and insurance and securities regulation
- J.D. degree, Franklin Pierce Law Center in Concord, New Hampshire; B.A. degree, Colby College in Waterville, Maine
- Can be contacted at [email protected]
Michelle Hobbs
Bakertilly
- Senior manager with Baker Tilly’s Virginia office and serves as a technical resource to client engagement teams
- More than 15 years of experience providing tax and consulting services to a variety of corporate enterprises
- Prior to joining Baker Tilly, she was a senior manager for a national public accounting firm where she managed tax services for several closely-held enterprises, specializing in government contractors and related entities and provided tax accounting services to small public entities
- Involved in the design of overall FIN 48 processes for publicly held entities; including the building of inventory tracking mechanisms, documentation of highly certain and uncertain tax positions, development of internal documentation processes and executive summaries of findings
- Member of the AICPA and the Maryland Association of Certified Public Accountants
- Masters of taxation degree, American University in Washington DC; B.S. degree, University of Maryland in College Park
- Can be contacted at [email protected]
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More Program Information
Why Lorman?
Over 37 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!
- OnDemand Courses
- Live Webinars
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- Course Manuals
- Executive Reports
- White Papers and Articles
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- State Specific Credit Tracker
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Questions? Call 877-296-2169 to speak with a real person.
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