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

• Special tax rules applicable to ESOPs for C corporations and S corporations, including deferral of gain by a selling shareholder and taxation of the business.
• Plan considerations for and financing of an acquisition, disposition, or a leveraged buyout.
• Benefits of employee ownership to shareholders, management, and employees, including interest alignment and improved motivation.

• Analyzing possible financial statement effects of IFRS with regard to compensation and benefits programs, including executive compensation, health and welfare, and retirement programs.
• Evaluating the potential impact of IFRS accounting on the operation of your rewards programs, especially those driven by corporate financial performance.
• Assessing IT and process changes, including information gathering, reporting, and internal controls.

• How the new statements affect tax accounting for uncertain tax positions, deferred taxes, and valuation allowances.
• Tax consequences at transition for past and prospective acquisitions.
• Fine-tuning tax due-diligence practices, including pressure points on effective tax rate, FIN 48 liabilities, and valuation allowances.

• Common weaknesses in tax provision processes, including tight timelines, data collection, and reliance on spreadsheets.
• Leading practices for improving the tax provision process, including the integration of current payable reconciliations, deferred tax account validations, alignment with compliance, and automation.
• Risk mitigation through the better management of people, process, and technology.

• Changes in terms of a debt instrument – what constitutes a “deemed” taxable exchange?
• Tax consequences from retirement of outstanding debt at a discount.
• Interest accruals and limitations for interest deductions on new debt.
• Recognizing losses, avoiding character mismatches, or limiting income on distressed debt before disposition by holders.

• Specific rules related to closed plants, impaired inventory, and other troubled assets, including impaired debt and accounts receivable.
• Opportunities to file for a quick refund to monetize net operating losses.
• Additional common method change opportunities that taxpayers should be familiar with.

• Legislative developments relating to a possible extension.
• Impact of the potential sunset on intercompany financing transactions and structural alternatives.
• Transactions that should be considered in light of the potential sunset of this provision.

• Brazil – issues associated with multinational companies investing and financing operations in Brazil, as well as repatriating profits.
• France – current trends in France under the new Sarkozy administration; and an update on R&D credits and the participation exemption regime.
• Key developments in other foreign jurisdictions.

• Recent sales factor market sourcing and increased sales factor weighting changes.
• New unitary combined reporting and consolidated filing methods.
• Working through the maze of safe harbor exceptions to the now more than 20 states that disallow certain related party expenses.

• Important legislation, including implications of this year's state budget law.
• Key cases involving combined reporting, apportionment, business purpose, and other hot issues likely to arise this summer.
• Important guidance from the state authorities regarding corporate partners, investment capital, and New York City audit statements.

• An overview of U.S. taxation of inbound investment, including rules of permanent establishment, effectively connected income, and FDAP – fixed, determinable, annual, or periodic income.
• Key state tax considerations – nexus versus permanent establishment, computing state taxable income, and earnings repatriation.
• Addressing exposure – location and timing of credits and incentives, possible hybrid and reverse-hybrid structures, and organizational issues.

• An overview of the U.S. wealth-transfer tax system and potential costs to private enterprise owners who don't plan ahead.
• How successful families have traditionally passed wealth through trusts and other tax-efficient vehicles.
• Why lower business valuations and interest rates near historic lows may provide favorable conditions for launching tax-efficient succession plans now.

• Assessing your overall vision and strategy for business succession and related issues, including identifying and preparing future leaders.
• Talents and skills the successor management team will need, and strategies and leading practices for addressing gaps.
• A case study illustrating how unseen obstacles can stall progress

• The five categories of reportable transactions, and when and how to disclose them.
• The price of non-compliance – understanding your potential penalty exposures.
• Approaches for avoiding reportable transaction penalties.

• Penalties most often asserted by examiners during an IRS examination.
• Potential defenses against these penalties.

• Legislative and litigation updates, and value chain structures that companies are using today.
• Issues states are attacking under audit, including economic substance, contractual gaps, and stale transfer pricing analyses.
• What companies can do to assess risks, steps for reducing exposure, options for strengthening structures, and addressing specific scenarios.

• Changes at the Canada Revenue Agency and updates on CRA positions regarding the penalty regime, audit positions, and qualified CCAs.
• CRA positions on U.S service regulations, royalty payments, intangibles, recharacterizations, foreign exchange, and plant closures.
• Options for appeals, Competent Authority, and APAs.
• The impact of current court cases on audit activity.

• Germany has new lower tax rates, but new rules also increase the tax burden on companies that shift operations to lower cost countries. How do you manage your position?
• Mexico's new flat tax may increase the tax cost of Mexican operations. How does the new IMMEX program offer opportunities to better manage Mexican profits?

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