FAS 109: FIN 48
Accounting for Uncertain Tax Positions - For Fund Managers


LIVE Webinar


Summary:

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.

Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Conference
Recommended CLE/CPE Hours: 2.0
(Please note, your State Bar or Accounting Board will make the final determination with respect to continuing education credit.)
Advance Preparation: Print and review course materials
Course Code: 083756


Featured Speakers for FAS109: FIN48 live webinar:

Grant Thornton LLP

Brian Moore
Tax Partner

BDO Seidman

Matthew Mullaney
Tax Partner

Ernst & Young LLP

Jeffrey N. Saviano
Tax Partner; Director of Northeast State and Local Tax Services

DLA Piper

Sang Kim
Partner


Event Talking Points:

SEGMENT 1:

Brian MooreTax PartnerGrant Thornton LLP

- 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

SEGMENT 2:

Jeffrey N. SavianoTax Partner; Director of Northeast State and Local Tax Services, Ernst & Young LLP

- 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

SEGMENT 3:

Matthew MullaneyTax Partner, BDO Seidman

- 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

SEGMENT 4:

Sang KimPartner, DLA Piper

- 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
- Accountants
- Controllers
- CFOs
- Presidents
- Vice Presidents
- Attorneys

Why Attend?

This is a must attend event for anyone interested in understanding FAS 109: FIN 48
- New guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A


Registration Information:

FAS 109: FIN 48
LIVE Webinar

Wednesday, September 3rd, 2008
1:00 pm to 3:00 pm (EDT)