FAS 109: FIN 48
Overview:Due to difficulties in meeting the compliance deadline, the FASB has postponed the operation of FIN 48 for private entities and hedge funds. Conflicts with the implementation, as well as the imposition of withholding taxes are just two of the issues the aforementioned entities are facing these days. That’s all about to change. This webinar will aim to provide private entities and hedge funds insights on how to systematically approach FIN 48 in their organizations.
The Knowledge Congress is assembling a panel of distinguished experts to discuss what these approaches are and how to avoid future conflict with the government.
<strong id="ep-name-of-speaker">Brian Moore, Senior Tax Manager,</strong>
<em id="ep-speaker-firm">Grant Thornton LLP</em>
- Evaluation of effectively connected income issues related to hedge funds
- State nexus issues related to hedge funds and private equity funds
- FIN 48 issues arising from failure to disclose certain transactions activities (i.e., 5471s, 8886s)
- Disclosure requirements for partnerships to limited partners
<strong id="ep-name-of-speaker">Jeffrey N. Saviano, Tax Partner; Director of Northeast State and Local Tax Services,</strong>
<em id="ep-speaker-firm">Ernst & Young LLP </em>
- Address process considerations including volume of jurisdictions
- Overview of common state and local FIN 48 issues identified
- Highlight some unique state and local tax technical and accounting issues
- Recommendations on maintenance and tracking of FIN 48 issues and law changes
<strong id="ep-name-of-speaker">Matthew Mullaney, Tax Partner,</strong>
<em id="ep-speaker-firm">BDO Seidman </em>
- Challenges to Implementation for Private Companies/Fund Managers
- FIN 48 Disclosure Requirements
- Impact of FIN 48 on Portfolio Companies of Private Equity Funds
- State and Local Considerations
<strong id="ep-name-of-speaker">Sang Kim, Partner,</strong>
<em id="ep-speaker-firm">DLA Piper </em>
- Taxable presence in non-US jurisdictions
- Deferral planning, capital gains and qualified dividend considerations
- Inversion and 956 issues
- Repatriation to service debt
Who Should Attend:
- Internal Controls and Finance Departments of Hedge Funds and Private Equity Groups
- Global Investment Managers
- Fund Management Companies
- Tax Managers
- Vice Presidents
Brian has more than 12 years of professional tax experience serving the financial services industry.
Brian has extensive experience providing a variety of tax planning and compliance services to both public and private businesses, including:
- Federal tax consulting and federal tax planning.
- Managing complex tax compliance projects with consolidated entities filing in multiple jurisdictions.
- Significant mergers and acquisitions experience including tax due diligence and structuring.
- Extensive FAS 109 and FIN 48 experience for public and private companies.
Brian has managed consulting and compliance engagements for hedge funds, fund of funds, private equity funds, offshore partnerships, financial institutions and bank holding companies.
Professional qualifications and memberships
- New York State Society of Certified Public Accountants
- Georgia Society of Certified Public Accountants
- North Carolina Association of Certified Public Accountants
- Association for Corporate Growth
Presentations and publications
Brian has been a frequent speaker for the Institute for Management Accountants and at industry events and conferences such as the Atlanta Tax and Legal FIN 48 Update.
Brian holds an MBA in Finance from Emory University and a BS in Accountancy from the University of Alabama.
Brian has more than 12 years of professional tax experience serving the financial services industry. Experience Brian has extensive experience …
Jeffrey N. Saviano is a Tax Partner with Ernst & Young and is the Director of the Northeast State and Local Tax Services Group in the New York City and Boston offices of the firm. Jeff rejoined Ernst & Young in 1996 and has over fifteen years of tax experience with “Big 4” public accounting firms. He concentrates his practice in the state income/franchise tax area and serves as a state and local tax advisor to numerous companies. His practice is focused on state tax risk mitigation, multistate tax planning, and transactional analysis.
Jeff is a Trustee for the Massachusetts Taxpayers Foundation, a non-partisan organization focusing on state spending and tax policies and the Massachusetts economy, and is a member of the Board of Directors of the Associated Industries of Massachusetts, and the Boston Municipal Research Bureau. Also, Jeff was a professor of State and Local Taxation within the Frank Sawyer School of Management at Suffolk University.
He has published articles regarding state and local tax policy and practice, including Pending Massachusetts Tax Legislation: Managing Change and the Need for a “Master Plan” published in the July, 2005 edition of the Journal of Multistate Taxation and Incentives. Jeff has testified before the Joint Tax Committee of the Massachusetts Legislature, and is a frequent speaker at taxpayer organizations and trade associations including: Massachusetts Taxpayers Foundation; New York University Institute on State and Local Taxation; Council on State Taxation (COST); Paul J. Hartman State and Local Tax Forum at Vanderbilt University; Georgetown Law State and Local Tax Institute; Massachusetts Society of CPAs; Tax Executives Institute; and the American Bar Association. He is also a regular commentator on tax policy matters for various media outlets.
Jeff earned a Bachelor’s Degree in accounting from Iona College, a J.D. from Syracuse University College of Law, and a Master of Laws in Taxation (LL.M) from Boston University School of Law. He resides in Wrentham, Massachusetts with his wife Lisa, son Matthew, and daughter Caroline.
Jeffrey N. Saviano is a Tax Partner with Ernst & Young and is the Director of the Northeast State and …
** Speaker Bio to be added soon.. **
** Speaker Bio to be added soon.. **
- Mergers and Acquisitions
- International Tax
- Life Sciences
- Tax Controversy
- New York University (1996) LL.M. Taxation
- Northwestern University School of Law (1995) J.D.
- Columbia University (1992) B.A. Philosophy and Economics
- New York
Sang Kim is a partner in the International Tax group and a member of the firm's National Diversity Committee. He concentrates his practice in international tax and operational structuring, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, post-acquisition integration, and international tax controversy.
He has led numerous international structuring projects for companies across a wide spectrum of industries and jurisdictions. Representative industries include high tech, consumer products, life sciences, outsourcing, manufacturing, and distribution. Within the high tech sector, he has extensive experience with clients in the semiconductor, software, and networking sectors. He has also worked extensively with clients doing business in China, India, Brazil, and other emerging economies.
Prior to joining the firm, he spent seven years at two of the Big 4 accounting firms in their Silicon Valley offices where he specialized in international tax from both planning and tax provision perspectives.
He is a frequent speaker on international tax matters for several organizations including the Council for International Tax Education (CITE), and the Alliance for Tax, Legal and Accounting Seminars (ATLAS).
- KPMG LLP
- Coopers and Lybrand LLP
PRACTICES – Tax – Mergers and Acquisitions – International Tax – Life Sciences – Tax Controversy EDUCATION – New York …
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