CPE Course Problematic Self-Directed Retirement Activities Series - Session 3: Prohibited Transaction Chinese Walls

October 23, 2017

1:00 PM — 2:40 PM

Location Webinar

Member Price $79.00
Non-member Price $109.00

Curriculum Taxation

Field of Interest

Level Intermediate

Designed For

CPAs, Attorneys, , Enrolled Agents, Other Tax Professionals

2.00 credits

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Objective

*Recognize the Peek Tax Court’s decision substantively requires correctly achieving management risk diversification policy compliance before accessing plan asset rule exception targeted benefits is enabled  

*Recognize the Ellis Tax Court’s decision substantively requires correctly achieving management risk diversification policy compliance before accessing plan asset rule exception targeted benefits is enabled  

*Recognize the Stephenson decision’s substantive holding means a correctly invoked plan asset rule operating company exception denies ascribing its underlying assets as plan assets and creates a Prohibited Transaction Chinese Wall (PTCW)  

*Recognize a PTCW correctly renders specifically proscribed self-dealing activities as generally infeasible on the PTCW’s exogenous side because there are no plan assets there  

*Recognize a PTCW correctly renders specifically proscribed self-dealing activities as generally feasible on the PTCW’s endogenous side because there are yet plan assets there  

*Recognize plan asset rule exceptions correctly include, inter alia, the operating company exception and the de minimis interest exception  

*Recognize whether plan entity investment correctly complies with Section 4975 impounded management risk diversification policy requirements  

*Recognize whether management risk diversification policy compliant plan entity investment properly invokes a plan asset rule exception  

*Recognize whether a Prohibited Transaction Wall has been correctly created between the plan’s entity investment interest and the entity’s underlying assets  

*Recognize whether Section 4975(c)(1)(A), (B), or (C) self-dealing activities have correctly transitioned to incidental benefits  

*Recognize when Section 704(b) transaction structures are correctly formulated they result in lower equity costs of capital while comporting with Congress’s retirement plan and going concern productivity policy objectives  

*Recognize when PTCW transaction structures are correctly formulated they result in transitioning proscribed self-dealing activities into incidental benefits

Highlights

*The Peek decision’s implications for management risk diversification policy compliance  

*The Ellis decision’s implications for management risk diversification policy compliance  

*The Stephenson decision’s implications for transitioning proscribed self-dealing activities into incidental benefits  

*Properly creating Prohibited Transaction Chinese Walls through management risk diversification policy compliance and properly invoking a plan asset rule exception  

*Direct versus indirect plan asset rule exception requirements

Instructors

Prerequisites

Complete the following webcasts— 1) Retirement Plan Management and Investment Risk Diversification Standards, and 2) Management and Investment Risk Diversification Indices.

Developer

ACPEN

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