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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Tax Issues and Planning Considerations for U.S. Executives: Pitfalls to Avoid and Best Practices for Tax Counsel

Deferred Compensation, Doctrine of Constructive Receipt, Section 83, Tax Consequences of Equity Compensation, Deductibility Rules

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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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.

Presented By

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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Credit Information

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

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

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


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, April 4, 2023

  • schedule

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

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

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

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.

BARBRI 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

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

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .