IRS Adopts

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Section 108(i) of the American Recovery and Reinvestment Act of 2009 permits C corporations and taxpayers engaged in business or trade to defer COD (Cancellation of Debt) income recognition for a period of 4-5 years. While making the 108(i) election has its advantages, one must carefully weigh the pros and cons before moving forward. In this Knowledge Group Section 108(i) LIVE webcast, a panel of distinguished professionals experts will help you understand the most critical issues which will include:

- Overview of the fundamentals
- Advantages and disadvantages of making the election
- Partnerships
- Timing issues
- Up-to-the-minute regulatory updates
- Live interactive Q&A session

This live webcast will provide tax and related professionals with a comprehensive overview of making the 108(i) election along with its pros and cons. Attending this course will give you the tools you need to understand how to make this election at your firm. Advanced registration is recommended as space is limited.

Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Group, LLC
Recommended CLE/CPE Hours: 1.75 - 2.0
Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.
Advance Preparation: Print and review course materials
Course Code: 093893
Recording Fee: $299 (Please click here for details)
NASBA Sponsor Number: 109004

 

Featured Speakers for Making the 108(i) Election live webcast:


Proposed Agenda (click here to view more)
SEGMENT 1:


Jonathan Zelnick, Principal in the Financial Institutions and Products Group,
KPMG LLP

** Speaker Talking Points to be added soon.. **

SEGMENT 2:


David B. Cubeta, Member,
Miller & Chevalier

I. Timing whip-saws from debt modifications.
    A. When a modification is a deemed exchange.
    B. Exchange consequences.
        1. Non-publicly-traded debt
        2. Publicly-traded debt.
    C. Section 108(i) election’s income deferral election.
    D. OID adjustments
II. Other possible topics
    A. Application of section 108(i) to a consolidated group when one member acquires another
        member’s debt.
    B. Sourcing consequences of COD income for the foreign tax credit.

SEGMENT 3:


David F. Levy, Partner, Tax,
Skadden, Arps, Slate, Meagher & Flom LLP

- Understanding The Advantages and Disadvantages Of Making A 108(i) Election
    - Different rules applicable to distressed corporations and distressed passthroughs provide
      different types of incentives to use or not use a 108(i) election to manage COD income
    - Discussion of situations in which a 108(i) election will prove beneficial
    - Discussion of situations in which other strategies may prove more beneficial than a 108(i)
      election
        - Bankruptcy process (prepackaged or non-prepackaged)
        - Reliance on another COD exception (e.g., insolvency, real estate, etc)
        - Abandonment of a distressed asset or entity
        - Tax efficient debt buyback strategies
    - Long term planning issues associated with a 108(i) election

SEGMENT 4:


Brian Knudson, Partner,
Ernst & Young, LLP

I. Application of Section 108(i) to partnerships

    A. Basic overview of statute.
        1. Applicable debt requirement for partnerships.
        2. Election at partnership level.
        3. Triggering of deferral upon certain transactions.
        4. Deferral of Section 752(b) distributions.

    B. Rev. Proc. 2009-37 and partnerships.
        1. Flexibility in determining amount of deferred income.
        2. Flexibility in allocating deferred income v. includible COD.
        3. Information reporting requirements.
        4. Other partnership related guidance.
        5. Remaining unanswered questions.



KPMG LLP
Jonathan Zelnick
Principal in the Financial Institutions and Products Group
speaker bio »»

Miller & Chevalier
David B. Cubeta
Member
speaker bio »»

Skadden, Arps, Slate, Meagher & Flom LLP
David F. Levy
Partner, Tax
speaker bio »»

Ernst & Young, LLP
Brian Knudson
Partner
speaker bio »»

Who Should Attend?

- CPAs, Corporate Tax Professionals & Finance Executives, Enrolled Agents
- Tax & Finance Attorneys, Corporate Counsel (Tax)

Why Attend?

This is a must-attend event for anyone interested in understanding Section 108(i)
- New guidance explained by the most qualified key leaders & experts
- Interact directly with the panel during Q&A

Registration Information:                                                                                                                                    


 

 

 

 


Making the 108(i) Election Pros & Cons Explained LIVE Webcast
Speaker Firms:








 

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Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.

Attention New York Attorneys:

This program is approved for CLE credit under New York’s Approved Jurisdiction policy. The Knowledge Group, LLC is an approved sponsor in the state of California, a New York Approved Jurisdiction. This program fulfills the non-traditional format requirement of exceeding 60 minutes in length. Please note only experienced attorneys (more than 2 years) are eligible to receive CLE credit via non-traditional format learning platforms. The Knowledge Group will verify attendance during the webcast via secret words (3 per credit hour) and by auditing attendees log in and log out records. All verification instructions will be provided during the webcast. Once attendance verification requirements have been completed, the attendee will be issued a certificate of attendance be The Knowledge Group for the course with the recommended number of credit hours. The Certificate of Attendance is normally sent via email in 24 hours or less.

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