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

Webinar: ID# 1015085
Recorded CD
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IRS CCA 201501013: Navigating New & Heightened Scrutiny Of Foreign Investment Fund Lending Income
About This Course:
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.
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IRS CCA 201501013: Navigating New & Heightened Scrutiny Of Foreign Investment Fund Lending Income
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