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Course/Product Description
Title:

IRS CCA 201501013: Navigating New & Heightened Scrutiny Of Foreign Investment Fund Lending Income

SKU:WC-1015085
Date / Time: Recorded
Format: Webinar
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Description:

IRS CCA 201501013: Navigating New & Heightened Scrutiny Of Foreign Investment Fund Lending Income

In a Chief Counsel Advice issued on Jan. 5, 2015, the IRS clarified its position regarding tax treatment of income from foreign investment fund lending.

Of particular interest is that this CCA signals that foreign investment fund lending partnerships will be subject to more aggressive oversight of their transactions. As a result, counsel must prepare now to advise clients on how to correctly structure fund lending activities.

The principal issue addressed by the CCA is the required designation of the activity’s net proceeds as income from a trade or business. Inaccurate characterization of this income could result in negative tax consequences for foreign investment fund clients. Counsel must be aware of the red flags that will result in a fund’s actions being considered a trade or business.

The CCA also provided important guidance in the maximization of available statutory safe harbors. Effective use of the safe harbors could result in avoiding the trade or business determination. The CCA further analyzed the use of the safe harbors as well.

Listen as our experienced panel reviews the clarifications provided by the recent CCA. Panelists will cover in detail the application of the trade or business designation to foreign investment fund lending as well as effective use of safe harbors. Additionally, attendees will benefit from a discussion on reporting and loan origination rules.

Outline

  • Context of CCA 201501013
  • Techniques for Avoiding U.S. Trade or business designation
  • Loan Origination
  • Fund Manager’s US business activities attributed to non-US investment funds
  • Safe harbor provisions
  • Reporting rules
  • Surviving expanded audits
Benefits

The panel will answer the following questions:
  • What considerations must be made when structuring foreign investment fund loans to avoid the trade or business designation?
  • What are the best practices to maximize the benefits of available safe harbors?
  • What techniques should be implemented when preparing for expanded tax audits within the context of foreign investment fund loans?
Learning Objectives

After completing this course, you will understand the application of the trade or business designation to foreign investment fund lending as well as effective use of safe harbors. Additionally, attendees will benefit from a discussion on reporting and loan origination rules.



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:CPE
All US States: 1.5

CLE
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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