American Law Institute Video Webcast
Program Chair and Speaker: Jerald David August
Why You Should Attend
Single-member disregarded entities are widely used for business, tax, and estate planning purposes to permit flow-through treatment of income for tax purposes and limit the personal liability of the single owner or member under state law. But the treatment of single-member entities may vary depending upon concept, and practitioners need to understand the full implications – and potentially disastrous surprises – of disregarded entities before advising clients on their use.
Join nationally recognized tax lawyer and ALI member Jerald David August as he examines the pros and cons of using disregarded entities for a range of tax planning purposes. This newly updated video webcast will also analyze the use of a defective entity in business acquisitions, in like-kind exchanges of real property, and in cross-border organizational structures and transactions.
What You Will Learn
This live video webcast will explore the following topics:
Definitional issues and concepts in forming a single-member entity for state law and federal income tax purposes; treatment for employment tax purposes
Elections to reverse tax treatment by filing Form 8832
Treatment of foreign organized entities under the check-the-box regulations
The Qualified Subchapter S subsidiary; the Subchapter S "defective entity"
Use of defective entities in business acquisitions and reorganizations
Use of "hybrid" and "reverse hybrid" entities in cross-border settings
Use of defective entities with respect to controlled foreign corporations
Treatment of interests in single-member entities for estate planning purposes
Questions submitted during the program will be answered live by the faculty. In addition, all registrants will receive a set of downloadable course materials.
Who Should Attend
This video webcast will benefit tax lawyers, business lawyers, estate planners, corporate counsel, accountants, and related professionals.