Tax Manager — Tax Planning & Strategy
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What you'll learn:
**Description**: Deep dive into the core principles of tax planning, emphasizing tax minimization strategies within legal and ethical boundaries. Explore various entity structures (C-corp, S-corp, LLC, partnerships, etc.) and their tax implications for different business scenarios. Consider cross-border implications. - **Resources or Activities**: Review IRS publications (e.g., Publication 334, Tax Guide for Small Business), read academic papers on effective tax planning, analyze case studies of successful and unsuccessful tax planning strategies, and draft preliminary entity selection strategies for hypothetical businesses. - **Expected Outcomes**: Solid understanding of tax planning principles, proficiency in analyzing entity structures, ability to evaluate tax advantages and disadvantages of each entity type, and an initial entity selection framework for various business situations.
Personal Notes:
What you'll learn:
**Description**: Master advanced tax research techniques, focusing on the use of primary and secondary sources (Internal Revenue Code, regulations, court cases, legislative history, IRS guidance). Learn to navigate complex tax law databases (e.g., LexisNexis, Westlaw) and interpret legal precedents. This includes understanding the weight of authority and applying it to complex tax scenarios. Practice finding and synthesizing information from diverse sources to support planning strategies. - **Resources or Activities**: Practice tax research using online databases, analyze court cases related to tax planning, and develop a research memorandum on a specific tax planning topic (e.g., deducting business expenses or determining depreciation). - **Expected Outcomes**: Mastery of tax research methodology, ability to use various databases, skill in interpreting and analyzing legal precedents, and proficient report writing skills to document research findings.
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What you'll learn:
**Description**: Focus on tax planning strategies for corporate transactions, including mergers, acquisitions, divestitures, and internal restructurings. Explore techniques for minimizing tax liabilities in these transactions, such as structuring deals to maximize tax benefits, minimizing gain recognition, and utilizing tax attributes. - **Resources or Activities**: Review tax law related to corporate reorganizations (Sections 351, 354, 368, etc.), case studies on M&A tax planning, analyze SEC filings to understand tax strategies of real-world deals, and develop a tax planning proposal for a hypothetical merger or acquisition. - **Expected Outcomes**: Deep understanding of tax issues related to corporate transactions, ability to structure deals to minimize tax liabilities, and proficiency in analyzing the tax impact of various transaction structures.
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What you'll learn:
**Description**: Delve into the specific tax rules for partnerships, limited liability companies (LLCs), and S corporations. Focus on planning techniques relating to partnership allocations, distributions, guaranteed payments, and Section 754 elections. Explore advanced S corporation topics such as shareholder compensation, built-in gains tax, and accumulated earnings tax. - **Resources or Activities**: Analyze the impact of Section 704(b) regulations, study case law on partnership disputes, and evaluate the effect of various S corporation distributions and compensation strategies. Draft a plan for a hypothetical partnership, LLC or S-Corp with a complex income stream. - **Expected Outcomes**: Proficiency in analyzing the tax implications of partnership and LLC operating agreements, knowledge of complex S corporation rules, ability to develop tax planning strategies specific to these entity types, and an ability to analyze flow-through entity taxation.
Personal Notes:
What you'll learn:
**Description**: Examine international tax planning, including topics such as transfer pricing, controlled foreign corporations (CFCs), global intangible low-taxed income (GILTI), and foreign tax credits. Explore strategies for minimizing global tax liabilities and managing cross-border transactions. - **Resources or Activities**: Review IRS regulations related to international tax, study case studies of international tax controversies, analyze transfer pricing documentation, and research the impact of the BEPS initiative. Develop a basic international tax plan for a multinational corporation. - **Expected Outcomes**: Understanding of key international tax concepts, ability to analyze the tax implications of cross-border transactions, knowledge of transfer pricing rules and documentation requirements, and familiarity with international tax planning strategies.
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What you'll learn:
**Description**: Understand the fundamentals of estate and gift tax, including gift tax exclusions, estate tax deductions, and the generation-skipping transfer (GST) tax. Explore tax planning strategies to minimize estate and gift tax liabilities and facilitate wealth transfer. - **Resources or Activities**: Review IRS publications on estate and gift tax, analyze estate planning documents (e.g., wills, trusts), and study case studies on estate planning strategies. Draft a basic estate plan for a high-net-worth individual. - **Expected Outcomes**: Knowledge of estate and gift tax rules, ability to analyze the tax implications of different wealth transfer strategies, and understanding of the importance of estate planning in tax minimization.
Personal Notes:
What you'll learn:
**Description**: Understand the tax controversy process, including IRS audits, appeals, and litigation. Learn to prepare for audits, respond to IRS inquiries, and represent clients before the IRS. - **Resources or Activities**: Review IRS procedures, study case law on tax disputes, analyze audit reports, and participate in a mock audit exercise. Prepare responses to hypothetical IRS inquiries. - **Expected Outcomes**: Familiarity with the tax controversy process, ability to prepare for audits, proficiency in responding to IRS inquiries, and an understanding of the importance of proactive tax compliance and documentation.
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