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Related party financings – Are you ready for the sweeping changes under IRC Section 385? (Part 1 of 2)

On April 4, 2016, the IRS and Treasury issued proposed regulations, under IRC Section 385, addressing whether an interest in a related corporation is treated as stock or indebtedness, or part stock and part indebtedness. The proposed regulations are a radical change from existing law and will impact all intercompany accounts. Once finalized, the new rules will require tax professionals to ensure that documentation is created at the time an advance is issued as well as during the entire time that it is outstanding. Will your intercompany debt be recast as equity, so that payments will be nondeductible dividends? Or will the debt be respected moving forward? Are partnerships exempt from the changes? Attend this 1st session of a 2-part session to learn about the impact these proposed regulations will have on your business's federal and state taxes and be prepared for the new documentation requirements before it’s too late.

Speakers:
Robert M. Gordon, Managing Director & Assistant General Counsel, True Partners Consulting LLC
Ron Tambasco, Managing Director, True Partners Consulting LLC

Moderator:
Roxanne Getz

Outrageous Cases

A review of state cases that defy logic, or at least defy logic more so than usual.

These cases will make professionals think twice as to whether or not the positions they take are on solid ground.

Speakers:
Theodore Bots - Partner, Baker and McKenzie LLP
David Hughes - Partner, Horwood Marcus & Berk Chartered

Moderator
Larry Ewing - CohnReznick LLP

A "101" level/primer course to the world of VAT and Indirect Taxes.

A primer course on VAT and Indirect Taxes that are used in numerous countries other than the US. Understanding the basics of these taxes could just keep your company - and you - out of some serious tax dilemmas!

Speakers:
Dr. Florian Hanslik PrimeTax
Eric van Noorloos Taxperience

Moderator
Jim Tauber Andersen Tax

Related party financings – Are you ready for the sweeping changes under IRC Section 385? (Part 2 of 2)

In this second part of a two-part session, learn about the IRS and Treasury issuance of proposed regulations under IRC Section 385 addressing whether an interest in a related corporation is treated as stock or indebtedness, or part stock and part indebtedness. The proposed regulations are a radical change from existing law and will impact all intercompany accounts. Once finalized, the new rules will require tax professionals to ensure that documentation is created at the time an advance is issued as well as during the entire time that it is outstanding. Will your intercompany debt be recast as equity, so that payments will be nondeductible dividends? Or will the debt be respected moving forward? Are partnerships exempt from the changes? Attend this 2nd session of a 2-part session to learn about the impact these proposed regulations will have on your business's federal and state taxes and be prepared for the new documentation requirements before it’s too late.

Speakers:
Robert M. Gordon, Managing Director & Assistant General Counsel, True Partners Consulting LLC
Ron Tambasco, Managing Director, True Partners Consulting LLC

Moderator
Diana Achim, Manager-Corporate Taxes, McDonald's Corporation

Ethics and Professional Standards for tax professionals

Part 1 of 2
This "interactive", 2.50 hour, session will examine in detail both the AB and AICPA Ethics Standards and model rules of professional conduct and Circular 230 rules that require certain standards from attorneys, CPA's, enrolled agents, and others who prepare tax returns and provide tax advise. It will provide insight into the ethics standards through specific examples and hypothetical situations designed to illustrate the rules and standards.

Speakers:
Jordan M. Goodman, Partner, Horwood, Marcus & Berk, Charted
Marilyn A. Wethekam, Partner, Horwood, Marcus & Berk, Chartered

Moderator
Vito Kivelaitis, CTC

What Time Is It - Time to Worry!

In the midst of everything you have on your plate, tax professionals need to be aware and knowledgeable about ticking time bombs before they go off. Specifically, agreements, obligations and requirements that often need to be updated or amended to take into account changes in business operations. This session will review the language commonly found in intercompany agreements, transfer pricing studies, tax sharing agreements, escrow accounts, unitary filings and incentive agreements and discuss best practices in monitoring and refreshing these agreements to avoid a showdown or other unpleasantness.

Speaker:
Lynn A. Gandhi, Partner - Honigman Miller Schwartz and Cohn LLP

Moderator:
Darren R. Lebiecki, Director-Corporate Tax - The Kraft Heinz Company

Ethics and Professional Standards for tax professionals - continued

Part 2 of 2
This "interactive", 2.50 hour, session will examine in detail both the AB and AICPA Ethics Standards and model rules of professional conduct and Circular 230 rules that require certain standards from attorneys, CPA's, enrolled agents, and others who prepare tax returns and provide tax advise. It will provide insight into the ethics standards through specific examples and hypothetical situations designed to illustrate the rules and standards.

Speakers:
Jordan M. Goodman, Partner, Horwood, Marcus & Berk, Charted
Marilyn A. Wethekam, Partner, Horwood, Marcus & Berk, Chartered

Moderator:
Vito Kivelaitis, CTC

Offshore Treasury Centers and Cash Management

Many companies use either notional or physical pooling to centralize their offshore cash in one location, hedge the currency risks associated with the deposits, and earn a better return on that cash than would be available if cash was held in a decentralized fashion across their global structure. Cash pooling structures raise a number of issues under U.S. and foreign law. Under U.S. law, concerns arise under section 956, sections 987/988, and the new proposed section 385 regulations. Under foreign law, some countries, like Canada, make cash pooling difficult or even impossible. Other countries raise beneficial ownership claims under applicable treaties. Our two speakers will walk through these challenges and address any new foreign currency rules that may be published between now and June 30th.

Speakers:
John D. McDonald, Baker & McKenzie, LLP
Josh Richardson, Baker & McKenzie, LLP

Moderator
Fuad Saba, Managing Director, FGMK, LLC

Presiding: Mike Kalata, President, The Chicago Tax Club

Speakers: All previous speakers

Review of Morning Topics – Questions and Answers