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Course/Product Description
Title:

Leveraging Outbound Transfers of Corporate Stock and Other Property

SKU:WC-1015078
Date / Time: Recorded
Format: Webinar
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Description:

In November 2014, the U.S. Internal Revenue Service (IRS) issued final regulations revising the reporting rules applicable to stock and property transfers under Internal Revenue Code §§367 and 6038B. The final regulations clarify the rules that apply for transfers of property to foreign corporations (outbound transfers).

U.S. or foreign persons use outbound transfers as a way to minimize or avoid U.S. tax on the profits from the sale. Under the final regs, the full amount of gain on an outbound transfer must be recognized only if a failure to comply with §367 reporting obligations was willful.

However, the final rules are not all a win for taxpayers. The final regs do away with a 2010 directive allowing for corrections in documents related to gain recognition agreement (GRA) filings. Further, §6038B now calls for specifics on FMV, basis and gain recognized when filing a GRA. Counsel and clients must carefully consider how outbound transfers should be utilized.

Listen as our authoritative panel discusses outbound transfers, IRC §367(a) and its gain recognition agreement requirements. The panel will also discuss the IRS final rules and reporting rules under Section 6038B, considerations for avoiding GRAs, and the final regulations.

Outline

  • Transactions that fall under IRC §367
  • IRS final rules (Nov. 2014)
  • Considerations for avoiding GRAs
  • Best practices for leveraging outbound transfers and minimizing taxes
Benefits

The panel will review these and other key issues:
  • When should a company file a GRA as part of an outbound transfer? When should they avoid filing a GRA?
  • How do the final regulations impact outbound transfers and GRAs?
  • What are the reporting requirements for outbound transfers? How did the final regulations change these requirements?
Learning Objectives

After completing this course, you will be understand:
  • What triggers require the filing of GRAs? When should GRAs seek to be avoided?
  • How do the final regulations impact outbound transfers and GRAs?
  • What are the reporting requirements for outbound transfers? How did the final regulations change these requirements?


Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. CPE Credit is available only for the LIVE webcast. Recorded versions do not qualify for credit.

Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.

Processing

To obtain CPE credit, attendees must participate in the live event, return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Credit Confirmation

Strafford will mail a certificate of credit within approximately 2 weeks of receiving an attendee's completed Official Record of Attendance—provided all required conditions have been satisfied.



Delivery

Handout materials and the phone number for live presentations are made available to you 1 day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CD's will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.

Cannot Attend The Live Presentation?

This presentation is also available in a recorded format, in CD version, as shown in the pricing options below.

About Webcasts / Audio Conferences / Podcasts:

Webcasts, audio conferences, and podcasts are presentations that you attend via the Internet, phone, or mobile device at a specified date and time for "live" versions, or at your convenience for "recorded" and "On-Demand" versions.

The live versions are interactive, meaning that participants can ask questions in real time, plus are a very cost-effective form of training because 1) you receive fast, convenient learning without any out-of-office time; 2) you can invite as many colleagues as you'd like to listen in on a single phone line; 3) you incur no travel expenses; and 4) you and your colleagues are back at work immediately after the session ends!

And though with recorded versions you do lose the ability to ask questions, you gain the ability to hear the presentation numerous times and to share it with others in your office.

Handout materials and the phone number for live presentations are made available to you prior to the event via email from the presenter and from the "MyAccount" link on the menu bar. Copies of the presentations are included with recorded versions.

Licenses / Designations / Educational Credits:CLE
All US States: 1.5

CPE
All US States: 1.5
About The Provider: Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417 or by visiting their website.

Strafford webinars and teleconferences offer an excellent opportunity to train your entire staff—with no lost travel time or expenses. They are extremely cost-effective—allowing an unlimited number of people at your location to listen from a single line at no additional charge.

Each live seminar features presentations by a panel of nationally recognized authorities, followed by an interactive Q&A session. Presentation materials can be viewed online or printed out. Audio can be accessed via the web or a telephone.
More Info: Contact Us For More Information
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