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December
4-5, 2008 |
Las
Vegas NV
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Register
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Thursday, DEC. 4, 2008
8:30 - 10:30 SPECIAL ISSUES WHEN TRANSFERRING PROPERTY TO A CONTROLLED
CORPORATION
Learn about the legislation and administrative rulings regarding transfers of property, including assumption of
liabilities, investment company rules, transfers of built-in losses, and treating certain stock as boot.
10:30 - 10:45 COFFEE BREAK
10:45 - 12:30 OVERVIEW OF RULES GOVERNING TAX-FREE REORGANIZATIONS
The rules governing the tax status of corporate reorganizations are a complex (some would say
nonsensical) regime. We will explain these rules in a
straightforward format with an emphasis on Treasury regulations that grant taxpayers significant flexibility
compared to prior law.
12:30 - 1:30 LUNCH BREAK
1:30 - 3:00 CONTINUATION OF TAX-FREE REORGANIZATIONS
Learn how to apply the complex reorganization rules to ensure non-recognition treatment. Attention is given
to the recently published regulations governing foreign mergers and related party reorganizations.
3:00 - 3:15 COFFEE BREAK
3:15 - 5:00 SECTION 355
After 1986, section 355 is the primary vehicle for moving assets out of a corporation without a tax. Learn about
the complex regime that permits this favorable taxpayer treatment and other rules that significantly limit the
benefits in the context of certain acquisitive transactions. We also review the recent
changes for determining if a corporation is engaged in an active trade or business.
5:00 DAY ONE ADJOURNS
Friday, DEC. 5, 2008
8:30 - 10:30 INTERNATIONAL RULES ASSOCIATED
WITH TAX-FREE ASSET TRANSFERS
Learn how to navigate the rules governing inbound, outbound, and foreign to foreign asset transfers under
section 367.
10:30 - 10:45 COFFEE BREAK
10:45 - 12:30 TAXABLE ASSET SALES AND SECTION 338(h)(10) TRANSACTIONS
Contrast taxable asset sales with tax-free asset reorganizations, and explore the world of “deemed” asset
acquisitions under section 338(h)10).
12:30 - 1:30 LUNCH BREAK
1:30 - 4:20 (15-minute break Included)
CONSOLIDATED RETURNS CONSIDERATIONS IN MERGERS & ACQUISITIONS
An introduction to various consolidated return issues that arise when consolidated groups are involved in
M&A transactions. Learn about elections to consider when acquiring or disposing of subsidiaries from a
consolidated group, as well as the recent guidance on loss disallowance.
4:20 CONFERENCE ADJOURNS
Chaired
by
Washington National Tax
- Corporate Tax Practice, KPMG LLP
Jeffrey
L.Vogel, Principal
Richard Bailine, Principal-in-Charge
Robert Liquerman, Principal
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View Brochure
ORDER A COURSE
NOTEBOOK:
All attendees
will receive our conference notebook free of additional charge at the
meeting.
Non-attendees may order notebooks and attendees may order
additional copies. Save shipping
& handling when you pre-pay! (Good
in U.S., U.S. possessions, and Canada.) U.S.
residents add
appropriate sales tax. Canadian residents add appropriate GST.
Be
sure to include the
conference title when ordering.
Order
Notebook-CLICK HERE
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