Learn How to Use the Check-the-Box Rules to Your Advantage
The final "check-the-box" (“CTB”) regulations, in effect since 1997, have significantly simplified the tax rules for determining whether an enterprise is considered a corporation, partnership, sole proprietorship or a branch for federal tax purposes. The regs have been very good news for taxpayers -- simplifying tax planning, eliminating certain tax traps, and avoiding the requirement of structuring partnership or LLC agreements primarily to avoid classification as a corporation. The CTB regs have also provided an unprecedented opportunity to reexamine existing structures that were created or used merely to accommodate technical legal requirements and whose business structure would be better served by operating in another form.
Over the past decade, this Entity Classification Regime has clearly evolved into one of the most significant tools in the tax practitioner’s planning arsenal with respect to flexibility in structuring both eligible domestic and foreign entities to meet the client’s legal needs as well as tax needs, especially where they might differ.
Join noted tax advisor, author and presenter, William "Bill" Elliot, CPA, ABV, LL.M., on Thursday, September 18, as he takes you step-by-step on a two-hour journey through what he considers the Top 10 aspects of this regime that tax planners must know in order to competently advise clients in creative, yet simple, approaches to maximizing the regime’s flexibility and avoiding its potential traps and pitfalls. Time will be provided for you to ask your most pressing questions directly to Mr. Elliott via phone or e-mail.
Program Topics
Bill Elliott’s “Top 10” coverage in this insightful seminar will include:
Key Features of the CTB Regime
Rules in a Nutshell
Wide Variety of Applications
Details of the Entity Classification Regulations on an Entity-by-Entity Basis
Creative Uses of Disregarded Entities
Emerging Trends in Multistate Tax Planning
Foreign Eligible Entities and a Prelude to International Tax Planning
Form 8832 Elections and Late Elections, Including Rev. Proc. and PLR Relief
Form 8858 and Annual Reporting of Disregarded Foreign Eligible Entities
Form 8865 and Annual Reporting of Foreign Eligible Entities Constituting Foreign Partnerships
Learning Objectives
Develop a solid understanding of the entity classification rules and their application
Determine when “disregarded status” is effective
Identify tax planning opportunities utilizing the CBT regime
Gain awareness of potential problem areas and pitfalls to avoid
Who Should Attend
All business tax professionals, financial managers, CPAs, enrolled agents, tax attorneys, tax return preparers, and other practitioners who advise businesses on tax and other financial matters will benefit from this insightful seminar.
Register today for this insightful program on Thursday, September 18 at 1 PM Eastern, Noon Central; 10 AM Pacific.
William (Bill) Perry Elliott, CPA, J.D., LL.M., ABV. is the head of the Mahoney Cohen & Company, CPAs’ International Tax and Consulting practice and a shareholder of the firm. Bill’s practice area extends to all aspects of international taxation, including domestic and offshore captive insurance companies, inbound and outbound entity transactions, estate and income tax planning for foreign persons in the U.S., transfer pricing, valuation of intangible and intellectual property for domestic and outbound transactions, including the design and formation of qualified cost sharing arrangements, specializing in the transfer of the non-U.S. exploitation rights in IP to foreign entities, trusts and estates, asset protection planning with domestic and international applications, valuations for tax purposes, captive insurance arrangements, and corporate and passthrough entity taxation and consulting.
Bill writes and edits extensively, including contributions to CCH’s TAXES: The Tax Magazine and 1120S Express Answers, the Journal of International Taxation, Tax Notes International, and other leading tax journals and publications. He also is developer of and contributor to self-study CPE programs in the areas of international tax, valuation and S corporations. Bill speaks both domestically and worldwide for state CPA societies and other leading U.S. tax and international tax programs directed to practitioners, as well as programs for individuals and companies needing technical and practical guidance in his areas of expertise.
Bill is an honors graduate of Millsaps College in Jackson, Mississippi, from which he received a B.A. in accounting degree. He also holds a Juris Doctor (J.D.) degree and Master of Law degree (LL.M.) in international taxation from St. Thomas University School of Law in Miami, Florida, from which he graduated summa cum laude. Mr. Elliott is a member of the AICPA and the Tennessee, Georgia, and Mississippi CPA Societies; and is licensed to practice as a CPA in New York, Alabama and Mississippi. Additionally, he is a credentialed business valuation and appraisal professional, holding the ABV (Accredited in Business Valuation by the American Institute of CPAs) and CVA (Certified Valuation Analyst from NACVA) designations. Mr. Elliott is also a member of the International Fiscal Association (IFA) based in the Netherlands.
Prior to joining Mahoney Cohen, Bill served as managing member of Decosimo Global, the international tax and consulting division of Decosimo, a regional CPA, finance and advisory firm. In addition to his international tax role, he was a tax principal at Decosimo, and a valuation practitioner within Decosimo Corporate Finance, a division of Decosimo CPAs.
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
Site License: $249 – Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. ($25 CPE fee additional for each person wishing to receive a CPE certificate for their participation.)
CD Recording: $249 – The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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