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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Wednesday, April 28, 2021

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax professionals guidance on key provisions of recently issued final IRC 162(f) and 6050X regulations. The panel will discuss applying the final regulations to fines, penalties, and other amounts, along with the requirements and exceptions. The panel will also discuss the impact of the new regulations and guidance on settlement agreements and payments.

Faculty

Richard Gagnon
Counsel
Shearman & Sterling LLP

Mr. Gagnon represents U.S. and international clients in audits and investigations before the Internal Revenue Service and the Department of Justice and in federal trial and appellate courts.

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Todd Lowther
Partner
Shearman & Sterling LLP

Mr. Lowther provides tax advice to clients on mergers and acquisitions, oil and gas transactions, and corporate and general business matters, including business formation, reorganization, and partnership and limited liability company structuring. He also has extensive experience in the structuring, organization, and capitalization of private equity funds, and frequently advises management teams from both a transactional and tax perspective. Mr. Lowther's experience includes a focus on the taxation of natural resources, partnerships, international joint ventures, and other transactions common in the petroleum industry.

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Description

On Jan. 12, 2021, the IRS issued final regulations on Section 162(f) and 6050X, as modified by the 2017 tax legislation, concerning the deduction of certain fines, penalties, and other amounts. Tax professionals must be aware of the implications, reporting requirements, exceptions, and other nuances of the new regulations.

The final regulations include several changes from the proposed regulations and finalizing provisions for governmental authorities, and provide taxpayers with guidance in negotiating and drafting settlement agreements. The regulations also address Section 6050X, which imposes reporting obligations on certain governmental authorities.

Before the 2017 tax reform, fines and penalties paid in connection with a violation of law were not deductible, except for payments made as compensatory damages, including single damages or remediation costs. Taxpayers are now prohibited from deducting any amounts paid or incurred to, or at the direction of, a government, governmental entity, or certain nongovernmental entities in response to a violation of law or potential violation of law, with few exceptions.

Listen as our panel discusses the tax treatment of settlements and judgments, implications of final IRC 162(f) and 6050X regulations, and offers strategies for negotiating and drafting settlement agreements in light of the new regulations.

Outline

  1. Overview of the tax treatment of settlements and judgment
  2. Recent case rulings
  3. IRS Final 162(f) and 6050X regulations
    1. Requirements
    2. Exceptions
    3. Reporting
  4. Key considerations in negotiating settlement agreements

Benefits

The panel will review these and other key issues:

  • What are the applicable rules regarding the tax treatment of settlements and judgments?
  • What is the impact of the recent final IRC 162(f) and 6050X regulations?
  • What are the requirements and exceptions under the new regulations?
  • What are the reporting and tax compliance challenges?
  • What are the key considerations for negotiating and drafting settlement agreements?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize key issues concerning the tax treatment of settlements and judgments
  • Understand the requirements and application of recent final IRC 162(f) and 6050X regulations
  • Ascertain tax planning methods to assist taxpayers in paying or receiving cash from settlements or judgments
  • Understand the reporting requirements for taxpayers and government authorities

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules for domestic and multinational businesses; supervisory authority over other preparers/accountants. Knowledge and understanding of filing requirements and penalties for non-compliance; familiarity with IRS processes for penalty abatement requests and settlement agreements.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).