Webcast: Income Tax Issues Arising From Endowment and Employee Plan Investments in Pass (XCITEEP117)
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Explore income tax issues arising from the investment of endowment and trust funds in pass-through alternative investments. Focus on unrelated business income tax (UBIT) relating to income from investments rather than operating business activities. Review debt financed income and discuss exceptions to acquisition indebtedness for qualified plans and schools. Also, discuss the state of UBIT rules. Federal and state rules differentiate between corporate and trust taxpayers with respect to tax rate

6/20/2017
When: 06/20/2017
1:00 PM until 4:00 PM
Where: Webcast
CALCPA
4173322A
United States
Presenter: Richard Ruvelson, J.D.


Online registration is closed.
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AcronymXCITEEP117
CPE3 hours
VendorCalCPA
Category
Taxation
LevelIntermediate
PrerequisiteKnowledge or experience in preparing or reviewing Form 990-T, or experience as controller, analyst, CFO or investment manager.
Adv PrepNone
Yellow Book?No
Designed forCPAs working with exempt organizations and professionals who are responsible for filing Form 990-T or are responsible for consulting on the taxation of investments and/or new revenue generating endeavors.
Registration
Member$90
CPA Non-Member$140

The Member rate applies to LCPA members, other state society members, and non-CPA staff of LCPA members. To register online, use the ‘Register’ button above. To register by phone, call the LCPA Member Service Center at 800.288.5272 or 504.464.1040, Monday through Friday, 8am to 5pm.

Course Description

Explore income tax issues arising from the investment of endowment and trust funds in pass-through alternative investments. Focus on unrelated business income tax (UBIT) relating to income from investments rather than operating business activities. Review debt financed income and discuss exceptions to acquisition indebtedness for qualified plans and schools.

Also, discuss the state of UBIT rules. Federal and state rules differentiate between corporate and trust taxpayers with respect to tax rates and contribution deduction rules. States differ regarding the return completion of UBIT, corporate or trust and/or tax rates. Allocations of activities to states may leave investors with a federal UBIT loss and positive taxable income or loss in some states. Discuss the relevance of blocker entities and the rules for filing and completing the following forms related to foreign holdings: Form 8865; Form 926; Form 5471; Form 8621 and FinCen Report 114.

Materials are provided as an ebook for this course.

Objectives

  • Review unrelated business income tax (UBIT)
  • Identify exclusions, modifications and exceptions to UBIT and their application to investment income
  • Discuss “S” Corporation issues
  • Identify debt financed income
  • Identify the “exception to the exception” for qualified plans and schools
  • Discuss blocker corporations
  • Recognize Form 990-T filing issues
  • Identify deductible investor expenses
  • Identify forms potentially required for foreign investing activity
  • Identify requirement for Form 990 Schedule F disclosure
  • Determine state UBIT filing requirements

Major Topics

  • Definition of unrelated business
  • Unrelated business taxable income modifications, exceptions and exclusions
  • “S” Corporation issues
  • Debt financed income
  • Schools and qualified plans acquisition indebtedness exception
  • Publicly traded partnerships
  • Blocker corporations
  • Investor deductions
  • Form 990-T
  • Filings relating to foreign investments Form 990 Schedule F
  • Corporations versus trusts
  • State taxation