Minimultinationals face all of the international tax complexities that juggernaut multinationals face - but without a battalion of tax professionals on payroll. How should an American entrepreneur abroad set up the business structure to minimize tax? This session will compare tax outcomes for everything from sole proprietorships to parent/subsidiary structures and make sense of the acronym soup of tax rules that apply.

The top 13 rulings of 2019 will be summarized along with their significance for compliance, planning and tax policy.

Gift Tax Returns are frequently viewed by tax professionals as the 'red headed stepchild'. They are often assigned to inexperienced preparers and overworked reviewers. They are fraught with dangerous hidden malpractice traps.

This session will analyze the various options that remain available to taxpayers for the disclosure of previously unreported foreign assets. We will compare the different legal standards applicable to each option and identify issues to be considered when correcting past non-compliance. Finally, we will also review current IRS international enforcement efforts.

Section 163j and the proposed regulations provide a new level of complexity for taxpayers with respect to their financing structure. This session will provide an overview of the section 163j rules for corporations and partnerships, and an overview of the interplay of section 163j with other tax reform provisions such as the BEAT and GILTI. This session will also highlight the nuances of section 163j that should be considered in debt financing structures.

With all the changes to loss limitations under Tax Reform, a refresher on all the loss limitations out there and traps for the unwary.

The Tax Cuts and Jobs Act (TCJA) has caused much upheaval all across the tax-exempt sector. Almost two years after its passage, confusion and uncertainty still remain. This session will provide an update on guidance on TCJA provisions and other legislative and regulatory changes impacting tax-exempt organizations.

This session assesses the numerous planning opportunities, traps, and unanswered questions that surface in the 199A final regulations relating to specified service trades or businesses (SSTBs). Attendees will also understand when and how to isolate and separate SSTBs from non-SSTBs.

Taxes and audits are a harsh reality for most companies, but for cannabis businesses they are especially brutal because of IRC §280E. Section 280E prohibits any deduction of business expenses if the taxpayer's trade or business consists of trafficking in controlled substances. Join this discussion to understand the nuances of tax, audits and 280E on the cannabis industry and how advisors can help clients better prepare. And, you’ll hear from the attorneys who are representing Harborside in the appeal of a Tax Court decision to the Ninth Circuit, which could have far reaching effects for the cannabis industry.

Practitioners often interact with family offices of clients and are sometimes asked to provide tax and legal advice with respect to the structure of family offices.  This session will provide a big picture primer for the tax practitioner who works with family offices and their functions. The session will discuss different types of family office structures, choice of entity, income and transfer tax planning, profits interests and governance considerations.