This message is sent to you by AccountingNewswatch

Tax Planning for Disregarded Entities: Issues, Risks, and Opportunities

Date: Tuesday, March 13, 2018
Time: 1:00 - 2:40 pm EST

Sponsored by Lorman Education Services

Registration - Live Webinar Only: $219.00

Registration - Live Webinar Plus CD Recording: $288.00


Gain a better understanding of the opportunities and pitfalls of using disregarded entities for a wide range of tax planning purposes.

The use of limited liability companies has proliferated both in the U.S. and elsewhere. The tax treatment of such entities by U.S. and foreign tax agencies has become increasingly complicated, and is often counter intuitive.

This topic will help you identify the appropriate classification of entities for U.S. and foreign tax purposes; determine the correct reporting requirements for such entities; understand the role of LLCs in structuring M and A transaction on a tax-free basis; and understand how foreign tax agencies classify U.S. LLCs.

Learning Objectives:

  • You will be able to explain the difference between the default classification rules for domestic and foreign entities.
  • You will be able to describe how to structure tax-free domestic M and A transactions using LLCs.
  • You will be able to discuss the advantages of using LLCs rather than corporate subsidiaries and why doing so avoids the complications that arise with consolidated tax return groups.
  • You will be able to identify the appropriate tax reporting forms for foreign owned LLCs.

This Live Webinar Covers These Hot Issues:

Classification Issues

  • U.S. Single Member Limited Liability Companies
    • Classification for Corporate Law Purposes
    • Classification for U.S. Income Tax Purposes Disregarded Entity vs. Corporation (C and S)
    • Classification for Employment Tax Purposes
    • Classification of U.S. LLCs for Foreign Tax Purposes
    • Reporting Requirements for Foreign Owned LLCs
  • Foreign Entities
    • Default Classification for Income Tax Purposes
    • Elective Classification for Income Tax Purposes

Consolidated Tax Return Issues

  • Corporate Subsidiaries
  • LLC Subsidiaries

Mergers and Acquisitions

  • U.S. M and A Transaction
  • Foreign M and A Transaction
    • Partnership Transactions
    • LLC Mergers
    • LLC Separations

Hybrid Entities and Withholding Tax Issues

  • Domestic Hybrids
  • Foreign Hybrids

Estate and Gift Tax and LLCs

Credit Information (Sponsored by Lorman Education Services):

  • CLE
  • CPE
  • AIPB

For Detailed Credit Information page click here

Only registered attendee will receive continuing education credit.

Instructor Profile:

Charles S. Kolstad, Mitchell Silberberg & Knupp LLP

  • Tax partner in the Los Angeles office of Mitchell Silberberg & Knupp, LLP
  • Advises clients, accountants, and business managers throughout the U.S. on the income tax issues and reporting requirements that arise when individuals or companies conduct business outside of the U.S.
  • Advises U.S. clients on structuring foreign business activities with a view to minimizing their global effective tax rate on foreign income
  • Advised nonresident aliens planning on moving to the U.S. on the U.S. tax reporting requirements that apply once they become a U.S. tax resident, pre-immigration planning to step-up basis of assets, eliminate U.S. tax on previously earned income, etc.
  • Frequent speaker on income tax and international reporting requirements, and regularly prepares tax bulletins on topical issues
  • During his career, he has been a tax partner at both Coopers & Lybrand LLP and Ernst & Young LLP
  • J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University

(Not available outside the US)