Tax Issues and Planning Considerations for U.S. Executives | CLE/CPE Course

BarbriSFCourseDetails

Course Details

Course Information

smart_display Format
On-Demand
signal_cellular_alt Difficulty Level
Intermediate
work Practice Area
Tax Law

Date & Time

event Date
Tuesday, April 4, 2023
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 webinar will provide tax professionals and attorneys guidance on critical tax issues and available planning techniques for U.S. executives. The panel will discuss income tax rules applicable to U.S. citizens, resident and nonresident aliens, application of Section 409A and Section 83, tax implications when the U.S. executive's employer is based in a tax haven, and issues stemming from equity awards and profits interests. The panel will also offer effective tax planning strategies aimed at minimizing adverse tax consequences of executive compensation.

Faculty

David M. Lehn

Partner

Withersworldwide

Mr. Lehn is a partner in the private client and tax team. He has extensive experience in federal and state income, estate and gift taxation. With his wide range of business and financial knowledge, clients look to him to apply his experience to structure complex business transactions and relationships and solve a variety of business-oriented problems while utilizing the benefits of trust, estate and tax planning. His clients include investors, entrepreneurs, senior level executives, family offices and fund managers and principals. His practice includes structuring investments and acquisitions, asset protection and preservation, and trust and estate planning.

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Description

There are several challenges faced by executives when determining the best tax planning mechanisms for their executive compensation structure. Tax counsel and advisers must have a thorough knowledge of the variety of forms executive compensation can take and applicable tax rules to avoid any unintended tax consequences for U.S. executives.

In addition to salaries and employee benefits, executive compensation can take several forms, including deferred compensation, granting profits interests, capital interests, and options to acquire such interests. Each arrangement has specific economic and tax implications that must be considered, such as ordinary income and capital gains tax rates, complex tax for non-tax-qualified deferred compensation, the doctrine of constructive receipt, acceleration of income recognition, and other key tax issues.

Also, tax counsel and advisers face additional challenges, including applying Section 83, carried interest taxation, special deductibility rules, and the golden parachute excise tax. These and other issues present planning and compliance challenges to carefully consider for U.S. executives or those subject to U.S. taxation despite their employers being based in a foreign jurisdiction.

Listen as our experienced panel offers a thorough and practical guide to tax planning considerations for U.S. executives, the application of Section 409A and Section 83, and issues stemming from equity awards and profits interests.

Outline

Applicable tax rules to consider for U.S. executives
Types of executive compensation options and alternatives for U.S. executives
Planning considerations under current tax law
Reporting and compliance challenges
Best practices to avoid unfavorable tax treatment

Benefits

The panel will review these and other key issues:

Tax challenges for U.S. executives and available planning strategies
Tax considerations for capital interest versus profits interest as equity compensation
Different tax planning methods based on the type of executive compensation options
Application of Section 83 and unvested interests
Section 409A and compensatory grants of equity interests
Best practices and critical considerations for U.S. executive compensation

NASBA Details

Learning Objectives

After completing this course, you will be able to:

Recognize the tax implications of capital interest versus profits interest as executive compensation
Acquire planning methods for different forms of executive compensation
Understand the application of Section 83 and Section 409A to grants of executive compensation
Recognize the tax treatment of carried interest and fee waivers arising from compensatory grants of equity interests

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, legal or public firm experience at mid-level within the organization, providing tax planning and preparing complex tax forms and schedules for partnerships and LLCs; supervisory authority over other preparers/accountants. Knowledge and understanding of corporate, partnership and LLC structures, equity compensation in these entities; familiarity with equity compensation alternatives and equity interest for employees, members and partners.

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.