Compensation & Benefits | FAS 109 | Federal Tax | International Tax | Multistate Tax | Private Companies | Tax Controversy | Tax Operations | Transfer Pricing

• An overview of worker and work classification issues, including how the government makes classification determinations.
• Insights into the recent landmark assessments and overtime judgments – what went wrong?
• Steps employers can take to protect themselves in the case of an audit.

• Achieving an effective equity award mix and using award size guidelines to reduce dilution.
• Share plan charge-backs – pushing costs out to subsidiaries internationally to secure foreign tax deductions and increase cash repatriation.
• Capturing tax benefits from your plan in selected countries, including the UK and France.

• Tax-related material weaknesses that still plague companies.
• Comparing the leading causes of tax-related material weaknesses today with those of prior years and what can be done to address them.
• Tax technical issues that potentially may lead to financial reporting restatements.
• The interaction between material weaknesses and restatements.

• Planning and design – analyzing old and new strategies to reduce employee costs with an eye toward future growth, and structuring benefits to retain valued employees.
• Implementation – creating a communications strategy for remaining and departing employees and helping departing employees make informed decisions about their offers.
• Ongoing issues – structuring the new workforce to maintain high productivity and align it with the business objectives.

• Why tax issues are critical – preserving tax attributes, managing cash taxes, and benefits of tax-efficient restructuring for the long-term.
• Phases of distress and their tax implications – underperforming, troubled, distressed, bankrupt, and post-reorganization.
• Tax milestones and deliverables along the bankruptcy timeline.
• Opportunities for future tax efficiency – avoiding unwanted ownership changes, tax-efficient changes to debt instruments, and addressing NOL limitations.

• Alternative transaction structures and their fact patterns that allow use of certain attributes to obtain a tax-basis step up for the purchaser.
• Rules on timing of income items and deductions, such as change of control deductions, transaction financing, and compensation-related items.
• Evaluating consequences of the transaction structure and assessing the most tax-efficient approach.

• An overview of the U.S. tax rules related to cross-border FX hedging.
• The subpart F implications of cross-border FX hedging transactions.
• The significant differences between the tax and U.S. GAAP treatment of FX hedging transactions and the identification and other threshold requirements.

• China – new M&A rules, financial incentives, and practical cross-border structuring and transactional issues.
• Singapore – update on tax incentives available for manufacturing, finance, intellectual property management, and other activities.
• Key developments in other foreign jurisdictions.

• Preparing your loss-year return, including differences between federal and state filing methods and NOL limitations in revenue-challenged states.
• Using NOL deductions on a carry-forward basis, including the possible discrimination against foreign-source dividends.
• How reorganization plans and divestitures can make you lose or mischaracterize NOLS.

• Timing of filing deadlines and implications of partial agreements, joint committee approvals, and settlements.
• Leading practices for meeting states' compliance requirements, including filing format and impact on state attributes, such as modifications and apportionment.
• Post-return submission issues, including accurate interest calculations for numerous years and offsets, credit and NOL adjustments, and incorporating non-RAR adjustments.

• The current environment – approaches states are willing to entertain, including settlements, prior audit errors rates, extrapolations, and managed audits.
• Evaluating the merits of these approaches based on your prior audit history, business consistency over time, and volume of sales and other transactions.
• Cutting-edge techniques for streamlining audits, including methodologies for more efficient data extraction, sampling, and modeling.

• FIN 48 requirements, planning timeline, and major tasks.
• Practical tips for implementation, including resources needs, an implementation framework, and key processes.
• Lessons learned from public companies, including leveraging FIN 48's benefits, states in which you might have unexpected tax liabilities, and the risks of implementing FIN 48 in a bubble.

• Depreciating the business aircraft – planning, problems, tips, and opportunities.
• Understanding the personal use disallowance provisions and minimizing their impact.
• FAA and Federal Excise Tax rules.
• IRS examinations – issues on which the government is focusing.

• IRS Issue Tiering strategy, including the process of resolving tiered issues.
• Delegation of settlement authority in Examination and Appeals.
• Impact of settlement guidelines in resolving issues in Examination and Appeals.

• Insights into the current environment at the IRS, which is focused heavily on international compliance, especially with regard to transfer pricing.
• Practical considerations in handling international examinations.
• Documentation requirements needed in defending IRS audits.

• Why indirect taxes matter – challenges and opportunities, retroactive and prospective.
• Recent law changes that are reshaping the indirect tax landscape, including the EU's new Value-Added Tax rules and Ontario's harmonization of goods and services tax.
• Leading practices in data management and technology enablers.
• Controlling burdensome compliance obligations.

• Tax's growing involvement in enterprise-wide risk management.
• How better integration of tax consequences can lead to more robust business decision-making.
• Laying the groundwork for managing tax risk and reward within your company's risk management framework.

• The importance of a life-cycle approach to defining the provision process.
• Identifying data drivers and weighing approaches to help capture important data at the right times.
• Getting the numbers right to facilitate sustainable accuracy and support scenario analysis.
• Assessing and selecting a technology tool.

• Recent developments at the state level, including new filing requirements and the trend toward third-party reviews.
• Assessing your current strategy and analyzing comparables and extraordinary adjustments to reflect a more appropriate allocation of profits.
• Non-traditional approaches to planning, including preaudit negotiations with states.

• Legislative developments in Mexico, Brazil, Argentina, and other key countries in the region.
• New information and documentation requirements and continuing scrutiny of new business models in Mexico.
• Hot audit issues, such as recent changes in audit processes and treatment of perceived abuses by various tax authorities.

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