Covington is pleased to offer this series of prerecorded webinars focused on recent tax developments. Registration is required for each seminar. We hope you will find the programs to be of value and encourage you to contact presenters with any questions you may have.

CLE: Each program is an intermediate/advanced level program. Lawyers who have been admitted to practice for a minimum of two years will be eligible for CLE credits in California - 0.5 General and New York - 0.5 Professional Practice (Transitional and Non-Transitional).

Attendees will need to record an attendee affirmation code and return the forms to Covington within 30 days of viewing the program. CLE credit available for one year after program release date. We will provide California, New York, and/or a Uniform Certificate of Attendance, where applicable.

Webinars:

Final Section 267A Regulations: Overview and Specific Issues Raised in the Examples

The final section 267A regulations, covering the disallowance of deductions on hybrid instruments and entities, are quite complex, and many of their nuances only come to light upon close inspection of the extensive regulatory examples. In this half-hour webinar, Covington Tax will brief you on the interesting and sometimes surprising points raised by certain examples, including traps for the unwary and practice pointers. The webinar includes a link to a background primer on section 267A, for those new to the section 267A regulations, as well as a link to a set of diagrams of all the regulatory examples for your reference.

The remote attendee affirmation and evaluations forms are accessible here, but also available in the on-demand console. CLE credit available for one year after publication date, 8/3/2020.

Speakers: Dirk Suringa and Shae Qian

Highlight of the Final FDII Regulations

This presentation will address the recently released final regulations on the foreign-derived intangible income (“FDII”) regime. We will provide a general overview of the FDII rules, with a focus on the significant changes made by the final regulations, including changes made to the applicability date, general computation issues, and the changes made to the documentation requirements. We will also discuss the effects of the final regulations on sales of general property, the sale or license of IP, and the provision of services.

The remote attendee affirmation and evaluations forms are accessible here, but also available in the on-demand console. CLE credit available for one year after publication date, 8/11/2020.

Speakers: Lauren Ross and Shae Qian

GILTI High-Taxed Exclusion: Final and Proposed Regulations

This presentation will address the recently released final and proposed regulations on the GILTI high-tax exclusion. We will provide a general overview of the rules that were proposed in 2019, as well as a discussion of the significant changes made by the final regulations. We will then provide an analysis of the cost and benefits of making the election, and finish with a discussion of the new proposed regulations that would extend certain aspects of the GILTI high-taxed exclusion to the existing subpart F high-tax exception.

The remote attendee affirmation and evaluations forms are accessible here, but also available in the on-demand console. CLE credit available for one year after publication date, 8/17/2020.

Speakers: Michael Caballero, Lindsay Kitzinger, and Jeff Lash

Section 165(i): Losses Relating to COVID-19

This presentation will address Section 165(i), which provides that any loss occurring in a disaster area and attributable to a Federally declared disaster may, at a taxpayer’s election, be taken into account in the taxable year immediately preceding the disaster. We will provide a general overview of section 165(i), and will discuss some of the technical and factual questions that arise in connection with applying section 165(i) to COVID-19 related losses. We will also discuss whether the election must apply to all COVID-19 related losses, or can apply selectively to only some. We will then discuss how to make the election, how to revoke it, and will suggest steps that can be taken now in order to prepare for an I.R.S. examination of issues relating to the election.

The remote attendee affirmation and evaluations forms are accessible here, but also available in the on-demand console. CLE credit available for one year after publication date, 8/31/2020.

Speakers: Lauren Ross

Interesting Times: Tax Controversy in the Era of COVID-19

This webcast will address how the current COVID-19 pandemic is affecting the U.S. and global tax controversy landscape. We will discuss domestic and international developments affecting tax controversy, how the IRS, DOJ, and U.S. courts are responding to the pandemic, and how tax authorities will approach examinations going forward, including what you can do to prepare.

The remote attendee affirmation and evaluations forms are accessible here, but also available in the on-demand console. CLE credit available for one year after publication date, 9/29/2020.

Speakers: Sean Akins, Kevin Otero, and Kandyce Korotky

Transfer Pricing Considerations in the Context of COVID-19

This webcast will address transfer pricing considerations in light of the current COVID-19 pandemic. After constructing a case study framework, we will analyze how U.S. and OECD transfer pricing guidance may be applied to common fact patterns resulting from the COVID-19 pandemic. We will also discuss whether taxpayers may rethink the pricing of transferred intangible assets in light of COVID-related business disruptions, including by application of the “commensurate with income” standard under section 482.

The remote attendee affirmation and evaluations forms are accessible here, but also available in the on-demand console. CLE credit available for one year after publication date, 10/19/2020.

Speakers: Kevin Otero, Lauren Ross and Joseph Sullivan