Transfer Pricing after the Tax Cuts and Job Act

Nov 12, 2018 2:45pm ‐ Nov 12, 2018 3:35pm

Identification: NTA1812

This session will discuss the changes in taxation for multinational corporations resulting from the Tax Cut and Jobs Act. The Global Intangible Low Taxed Income ("GILTI) tax, Foreign Derived Intangible Income ("FDII") deduction and the Base Erosion Anti-Abuse Tax ("BEAT") as well as potential ways for transfer pricing to mitigate the impact of these changes will be discussed.

  • Recognize the international tax aspects (GILTI, FDII, BEAT) of the Tax Cut and Jobs Act.
  • Analyze how transfer pricing methods can be utilized to mitigate impact of these changes.

The New Partnership Audit Regime has Arrived

Nov 12, 2018 3:45pm ‐ Nov 12, 2018 5:25pm

Identification: NTA1814

On January 1, 2018, a new age dawned as the Centralized Partnership Audit Regime officially took effect. Virtually every partnership (from 2 to 100,000 or more partners) will be subject to the new rules if placed under audit. Learn all about the limitless power of the Partnership Representative (and how to limit it). Follow along as we navigate the twisting trails of the modification period and explain the difference between the “pay-up”, “pull-in” and “push=out” options available. You’ll hear about the challenges issues faced by the states to conform to the new rules and collect their share of tax on any audit adjustment, as well a the actions taken by them so far.

  • Recognize the new centralized partnership audit regime
  • Recognize the options for opting out of the regime
  • Identify options for passing adjustments to partners
  • Understand the critical importance of the Partnership Rep
  • Learn about how the various states are or are not conforming to the federal approach

Putting It On & Taking It Off: Managing Tax Basis Today (For Tomorrow)

Nov 12, 2018 3:45pm ‐ Nov 12, 2018 5:25pm

Identification: NTA1815

Now that “tax reform” has arrived, the importance of (and the opportunities surrounding) the management and creation of tax basis has never been greater. This presentation will discuss innovative tax basis management techniques that strip, shift, create, concentrate, and maximize basis where it can be of most benefit to taxpayers.

  • Identify upstream planning and powers of appointment to create basis
  • Recognize maximizing and multiplying the “step-up” in basis
  • Determine the upside of leverage
  • Partnership planning to move basis to where you want it
  • Uses of grantor trusts and disregarded entities to move basis
  • How to “base-up” foreign assets for U.S. taxpayers

Building by Example: QBI Case Studies

Nov 12, 2018 3:45pm ‐ Nov 12, 2018 5:25pm

Identification: NTA1816

Attend this session to apply the knowledge gained from earlier sessions in computing the Section 199A Qualified Business Income Deduction available to the taxpayer. Participants will be provided assumptions for examples, from the less complex to the more complex, in learning how the QBID will benefit clients. This will lead the participant to determine if alternative entity structures and arrangements might increase the client’s deductions.

At the end of this session, the participant should be able to:

• Distinguish QBI from non-QBI
• Recognize the overall limitation to arrive at the deduction in computing taxable income
• Determine if income from a specified service business qualifies as QBI
• Apply the limitations of wages and investment in qualified property in arriving at the QBID for a high income taxpayer


Tax Cuts and Jobs Act Impact on Real Estate

Nov 12, 2018 3:45pm ‐ Nov 12, 2018 5:25pm

Identification: NTA1817

A discussion of the new tax law changes affecting real estate and partnerships under the Tax Cuts and Jobs Act, including the 20% deduction for qualifying business income, changes affecting carried interests, cost recovery and expensing changes and business loss and interest expense limitations.

  • Recognize the aspects of the Tax Cuts and Jobs Act as it affects real estate.
  • Identify planning opportunities and new risks associated with the tax law changes under the ACT.

What is AICPA Advocating For You?

Nov 13, 2018 7:00am ‐ Nov 13, 2018 7:50am

Identification: NTA18203

During this interactive session, learn how the AICPA solicits input from its members, develops official positions, and serves the public interest by advocating sound tax policy and effective tax administration. This session also addresses the current political climate in Washington that may affect you or your clients.

Recognize the following:

  • The tax law changes and the ongoing tax reform initiatives of interest to the AICPA
  • The AICPA's advocacy efforts related to the Tax Cuts and Jobs Act and recent Treasury regulations
  • The latest developments in AICPA's advocacy efforts related to tax administration issues

Transition Your Practice From Tax Preparer to Trusted Advisor

Nov 13, 2018 7:00am ‐ Nov 13, 2018 7:50am

Identification: NTA18204

Attendees at this session will walk away with the knowledge of how to change their practice from that of compliance to that of advisor. The steps taken in their process will be identified and explained so that attendee will be able to change their model of doing business. Value Pricing and Fixed Pricing are the choices for those who change their models.

  • To be able to switch from a compliance provider to a reliance provider to understand the benefits of bundled and value pricing

Planning for the Choice of Entity in the World of Tax Reform: Part I

Nov 13, 2018 10:40am ‐ Nov 13, 2018 11:30am

Identification: NTA1821

This two-part session is a townhall format for participants to ask the pressing questions associated with choosing the appropriate entity structure in which to operate a business.

At the end of this session, the participant should be able to:

  • Recognize double taxation doesn’t apply to all C corporation shareholders
  • Identify business types and scenarios which might benefit from filing as C corporations
  • Recognize the inherent difficulties of a changing tax environment in entity planning services
  • Describe scenarios in which flow-through taxation is more favorable than C corporation taxation

Elder Planning

Nov 13, 2018 10:40am ‐ Nov 13, 2018 11:30am

Identification: NTA1822

America is aging. The fastest growing segment of our population is the age 65 and over category. As people age, they confront myriad financial and health care issues. The speaker will discuss these issues and offer various solutions. Relevant tax considerations will also be addressed.
  • Identify the needs of our aging population so that relevant issues can be identified and addressed.

Foreign Disclosure Issues: Fixing the Past and Getting it Right for the Future

Nov 13, 2018 10:40am ‐ Nov 13, 2018 11:30am

Identification: NTA1823

This session will analyze the various options available to taxpayers for disclosures to the IRS of previously unreported foreign assets in light of the closure of the Offshore Voluntary Disclosure Program in August 2018. We will compare the different standards applicable to each option and identify the issues to be considered when correcting past non-compliance. Also current IRS international enforcement efforts will be analyzed.

  • Identify the factors to be considered when taxpayers disclose past non-compliance.
  • Recognize the current options available to the IRS for enforcement of foreign reporting requirements.
  • Analyze when legal counsel must be considered.