Tax Manager — Tax Research & Analysis
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What you'll learn:
**Description:** This day focuses on establishing a strong foundation in tax research. Explore various research methodologies, including primary and secondary sources, and learn to effectively utilize tax research tools. - **Resources/Activities:** - Review the hierarchy of tax law: Internal Revenue Code, Regulations, IRS rulings (revenue rulings, revenue procedures, private letter rulings, etc.), court cases (Tax Court, District Courts, Circuit Courts, Supreme Court). - Analyze different tax research databases (CCH, RIA Checkpoint, Bloomberg Tax, Westlaw). Learn their unique features and how to navigate them efficiently. - Practice formulating research questions and developing effective search strategies. - Examine the use of citators (Shepard's, KeyCite) for case validation and analysis. - **Expected Outcomes:** Solid understanding of the tax research process, proficiency in using tax research databases, and the ability to formulate effective research questions.
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What you'll learn:
**Description:** This day delves into analyzing complex corporate tax issues. Focus on understanding the tax implications of different business structures (C Corporations, S Corporations, Partnerships, LLCs), including their formation, operation, and liquidation. - **Resources/Activities:** - Case studies involving mergers & acquisitions, reorganizations, and spin-offs. - Review relevant sections of the Internal Revenue Code (e.g., Sections 351, 368, 302, 304). - Analyze the tax implications of different types of financing (equity, debt, convertible debt). - Learn to identify and mitigate potential tax risks associated with complex transactions. - **Expected Outcomes:** Ability to analyze the tax consequences of various corporate transactions, understand the nuances of different business structures, and identify potential tax risks.
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What you'll learn:
**Description:** Focus on industry-specific tax challenges. Choose a few industries (e.g., real estate, financial services, technology) and research key tax issues prevalent in each. - **Resources/Activities:** - Deep dive into industry-specific tax publications and guides. - Analyze IRS guidance, court cases, and rulings relevant to chosen industries. - Research specific topics within each industry (e.g., Qualified Opportunity Zones in real estate, financial product taxation in financial services, intellectual property taxation in technology). - Participate in industry-related webinars or online discussions. - **Expected Outcomes:** Specialized knowledge of industry-specific tax issues and the ability to apply research methodologies to complex, real-world scenarios.
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What you'll learn:
**Description:** Explore the detailed aspects of tax accounting methods and the principles that govern them. Gain in-depth knowledge on the accounting for different tax concepts. - **Resources/Activities:** - Explore permissible and required methods of accounting. Review IRS guidelines such as the Automatic Change in Accounting Methods (Form 3115). - Examine specific accounting methods for various items, like inventory valuation, depreciation, and long-term contracts. - Compare and contrast differences between accounting for book versus tax purposes. - Analyze related topics such as LIFO, FIFO, and capitalization vs. expensing. - **Expected Outcomes:** Deep comprehension of tax accounting methods, their specific rules, and how they apply to various aspects of a business's financial activities.
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What you'll learn:
**Description:** This day will shift to a crucial aspect of tax law: estate and gift taxation. Review federal estate tax, gift tax, and generation-skipping transfer tax principles. Focus on planning strategies. - **Resources/Activities:** - Study estate tax calculations, gift tax exclusions, and generation-skipping transfer tax. - Research strategies such as irrevocable life insurance trusts (ILITs), qualified personal residence trusts (QPRTs), and family limited partnerships (FLPs). - Investigate current case law and rulings involving estate and gift tax valuation issues. - Analyze related state estate and inheritance tax laws. - **Expected Outcomes:** Knowledge on estate and gift tax principles, comprehension of relevant planning strategies, and an understanding of current valuation challenges.
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What you'll learn:
**Description:** This day focuses on international tax. Cover basic international tax concepts, including transfer pricing, controlled foreign corporations (CFCs), and the Foreign Account Tax Compliance Act (FATCA). - **Resources/Activities:** - Research relevant sections of the Internal Revenue Code (e.g., Subpart F, Section 965). - Review tax treaties and their implications. - Analyze transfer pricing regulations and documentation requirements. - Study case studies involving cross-border transactions and tax planning strategies. - Familiarize with the OECD initiatives and their effects on global taxation. - **Expected Outcomes:** Understanding of international tax principles, including transfer pricing, CFCs, and FATCA, and the ability to analyze complex cross-border transactions.
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What you'll learn:
**Description:** This final day covers tax controversy and ethics. Explore the process of dealing with tax audits, administrative appeals, and tax litigation. Learn about ethical considerations in tax practice. - **Resources/Activities:** - Review the IRS audit process and strategies for responding to audit inquiries. - Understand the process of administrative appeals and tax court litigation. - Study Circular 230 and ethical standards for tax professionals. - Research recent tax court cases and analyze the court's reasoning. - Consider penalties and defense strategies in tax controversies. - **Expected Outcomes:** Understanding of tax controversy processes, knowledge of ethical standards, and the ability to navigate potential tax disputes effectively.
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