Monday, May 14, 2018

Tomorrow: Section 338(h)(10) Elections – After the Tax Cuts and Jobs Act

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Section 338(h)(10) Elections – After the Tax Cuts and Jobs Act
May
 
15
1 pm - 2:30 pm ET
Presenter: Stephen Phillips, senior partner at Phillips Golden LLP
Credits: CPE, CLE in all states (Credit Details)
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Course Description
 
The Tax Cuts and Job Act ("TCJA") delivered enhanced cost recovery options for business assets. Asset acquisitions, including "deemed" asset acquisitions of entire corporate businesses under IRC Section 338, have garnered increased attention. In this practical webinar, you will learn how to guide and help your clients with proper tax acquisitive planning. Upon course completion, you will be able to describe:
  • The impact of "TCJA" on the world of acquisitions
  • How Sec. 338, particularly the "(h)(10)" election, provides an appealing tax framework for acquisitions for both regular and electing small business ("S") corporations
  • The mechanics of the various elections available under Sec. 338, focusing on the (h)(10) election, and the relatively new "IRC 336(e") election
  • Pre-transaction planning and concerns for the likely target corporation (especially an S corporation)
  • "338-friendly" transactions, including due diligence guidance for the potential acquirer
  • Valuable options under the IRC Section 336(e) election
  • Key negotiation points and agreement provisions to ensure a successful and solid Sec. 338 acquisition
  • Pitfalls that might arise under state tax laws
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The Presenter
About The Presenter
 
Stephen L. Phillips is the senior partner at Phillips Golden LLP, a tax, real estate, and transactional boutique law firm. Mr. Phillips is an experienced tax and transactional attorney who helps entrepreneurs and investors start, grow, and exit their businesses and investments in a tax-wise manner in the U.S. and beyond. Mr. Phillips is Board Certified in Tax Law through the Texas Board of Legal Specialization.
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