This is the fourth installment of TIP on Tax, a series from Grant Thornton LLP’s Technology Industry Practice (TIP). The series introduces key tax issues for dynamic technology companies. In our first article, we explored strategies for managing net operating losses (NOLs) generated in the startup phase. More at: http://gt-us.co/TIPonTax
DOL fiduciary rule: How it affects the insurance industry Grant Thornton LLP
We explore how the Department of Labor's final rule expanding the definition of fiduciary investment advice for advisers to retirement plans, participants and beneficiaries will affect the insurance industry.
As today's not-for-profit organizations shift from being purely mission focused to operating more “like a business,” certain core principles and fundamentals apply to both. To wit, it is vital for audit committee members to stay ahead of relevant changes to legal and regulatory requirements in this challenging environment. Take a look.
After the acquisition: 5 steps to manage the tax processGrant Thornton LLP
A detailed plan is critical to accomplishing all the tax-related tasks that need to occur in the months after an M&A transaction closes. Your 100-day plan for managing the tax process should include five key steps.
Why prepare now? 5 things that smart businesses are doing TODAY to prepare fo...Grant Thornton LLP
Tax reform is top of mind for many of today’s businesses as they struggle to understand what it might mean to them, and what they should be doing to prepare. While it may be easy to be paralyzed by the uncertainty of the legislative process, a “wait-and-see” approach is a mistake. The prospect of tax reform creates tremendous new tax planning opportunities, and many of these are effective only if done before tax reform is enacted. No company should be making long-term business decisions without understanding how tax reform could affect the economic impact. Learn the five steps your business can take now to prepare for tax reform.
Asset Management Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
Though hedge fund volume has doubled in the past five years, fees are pressured down; responsive strategies to replace fee dependency include expansion — M&A, joint ventures and alliances.
ForwardThinking is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
Election-year politics are dominating legislative action this year as both parties lay down
policy agendas for 2017 and beyond. President Obama and the Republican leaders of Congress are offering competing plans on how to reform the US tax system and
to promote other policies intended to increase economic growth and make American companies more competitive. At the same time, both Democratic and Republican candidates seeking their party’s presidential nomination are advancing tax reform plans.
DOL fiduciary rule: How it affects the insurance industry Grant Thornton LLP
We explore how the Department of Labor's final rule expanding the definition of fiduciary investment advice for advisers to retirement plans, participants and beneficiaries will affect the insurance industry.
As today's not-for-profit organizations shift from being purely mission focused to operating more “like a business,” certain core principles and fundamentals apply to both. To wit, it is vital for audit committee members to stay ahead of relevant changes to legal and regulatory requirements in this challenging environment. Take a look.
After the acquisition: 5 steps to manage the tax processGrant Thornton LLP
A detailed plan is critical to accomplishing all the tax-related tasks that need to occur in the months after an M&A transaction closes. Your 100-day plan for managing the tax process should include five key steps.
Why prepare now? 5 things that smart businesses are doing TODAY to prepare fo...Grant Thornton LLP
Tax reform is top of mind for many of today’s businesses as they struggle to understand what it might mean to them, and what they should be doing to prepare. While it may be easy to be paralyzed by the uncertainty of the legislative process, a “wait-and-see” approach is a mistake. The prospect of tax reform creates tremendous new tax planning opportunities, and many of these are effective only if done before tax reform is enacted. No company should be making long-term business decisions without understanding how tax reform could affect the economic impact. Learn the five steps your business can take now to prepare for tax reform.
Asset Management Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
Though hedge fund volume has doubled in the past five years, fees are pressured down; responsive strategies to replace fee dependency include expansion — M&A, joint ventures and alliances.
ForwardThinking is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
Election-year politics are dominating legislative action this year as both parties lay down
policy agendas for 2017 and beyond. President Obama and the Republican leaders of Congress are offering competing plans on how to reform the US tax system and
to promote other policies intended to increase economic growth and make American companies more competitive. At the same time, both Democratic and Republican candidates seeking their party’s presidential nomination are advancing tax reform plans.
For private software deals, determining working capital can be tricky. Here, we will explain (from the seller’s perspective), the basics of the working capital adjustment; discuss some pitfalls; and takeaways.
Managing Director Christopher Recor takes part in an expert forum discussion of sanctions compliance. This is a reprint from the July – September 2015 issue of Risk & Compliance Magazine.
GT Events and Program Guide is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
This publication includes the deal activity in the insurance sector such as overall highlights, key announced transactions, and the outlook ahead. Read our full report to learn more.
Stakeholder management in getting the deal doneBrunswick Group
It is probably a lazy truism that regulatory and political clearance has become the most challenging and unpredictable factor in executing complex, crossborder mergers and acquisitions.
This article originally appeared in DealMakers magazine
Technology Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
Technology leaders are making bold decisions and reinventing their company, exploiting innovative technologies, sharpening a competitive edge, investing significantly in R&D, embracing a new business model and taking a more strategic view of risk.
Provider/payor convergence: A prescription for growth?Grant Thornton LLP
As bottom lines shrink, payors and providers are beginning to see convergence, or vertical integration, as the path to growth, Panelists from Johns Hopkins Institutions, Buchanan Ingersoll & Rooney PC and Grant Thornton LLP share their experience.
The Retirement Landscape: Technical and Legal UpdateBPAS
The DoL’s proposed fiduciary regulation is the most controversial ERISA initiative since the enactment of the statute in 1974. If adopted as proposed, the regulation will have significant impact on financial institutions selling products to IRAs and 401(k) plans. The proposed changes would essentially open up the $7 trillion IRA market to ERISA, impacting the sale of investment products, from mutual funds to variable annuities, to IRAs. The proposal would also change the definition of an “advice fiduciary,” making it easier for the DoL to assert claims against persons or entities selling investment products or gathering assets.
In this session, we’ll discuss the impact of the DoL proposal for your business, from the stand-point of what needs to be changed to make the proposal “workable” and what you’ll need to do to comply if the proposal is adopted without change. Specifically, this session will focus on:
Changes to the definition of Investment Advice Fiduciary
Fiduciary status “carve-outs” for sales presentations
The new Best Interest Contract Exemption for IRAs
Changes to PTE 84-24 and other Exemptions
Guest Speaker: Steve Saxon, Principal, Groom Law Group
Real Estate Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
REITS are finding that while online shopping is active, their real estate holdings — stores and malls — continue to draw actual shoppers. Most sales still take place in brick-and-mortar, with technology shaping retail and real estate success.
For digital media companies, effective cybersecurity programs a mustGrant Thornton LLP
In digital media trust is everything, without it your business model doesn’t work. Cybersecurity can be a key component, ensuring the integrity of your services. Check out this brief guide to securing your data.
Dodd-Frank's Impact on Regulatory ReportingHEXANIKA
We previously analyzed how Dodd-Frank and how the new regulations have impacted large banks as well as midsize and small banks. This time, we will look at how the law meant to address one issue (avoid a financial meltdown similar to 2008) might have created other challenges for banks – the most important one that of regulatory reporting:
With these key best practices, you can create strong ERP governance that will help you use your platform effectively, with an increased focus on the strategic objectives of your business.
Learn more - http://gt-us.co/1NJKpfZ
My books- Learning to Go https://gumroad.com/l/learn2go & The 30 Goals Challenge for Teachers http://amazon.com/The-Goals-Challenge-Teachers-Transform/dp/0415735343
Resources at http://shellyterrell.com/games
Keynote address (Feb, 2016) to the educators in the Fort Nelson school district. We all know that we cannot teach a child without a concection... without a relationship. In the hustle and bustle of our jobs as educators, we often forget our why, the reason we got into education, of trying to make a difference with kids. In this talk, 6 Keys to Connecting are shared and discussed with the challenge of creating a more positive climate and better connections with kids in our classrooms, schools, and organizations.
For private software deals, determining working capital can be tricky. Here, we will explain (from the seller’s perspective), the basics of the working capital adjustment; discuss some pitfalls; and takeaways.
Managing Director Christopher Recor takes part in an expert forum discussion of sanctions compliance. This is a reprint from the July – September 2015 issue of Risk & Compliance Magazine.
GT Events and Program Guide is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
This publication includes the deal activity in the insurance sector such as overall highlights, key announced transactions, and the outlook ahead. Read our full report to learn more.
Stakeholder management in getting the deal doneBrunswick Group
It is probably a lazy truism that regulatory and political clearance has become the most challenging and unpredictable factor in executing complex, crossborder mergers and acquisitions.
This article originally appeared in DealMakers magazine
Technology Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
Technology leaders are making bold decisions and reinventing their company, exploiting innovative technologies, sharpening a competitive edge, investing significantly in R&D, embracing a new business model and taking a more strategic view of risk.
Provider/payor convergence: A prescription for growth?Grant Thornton LLP
As bottom lines shrink, payors and providers are beginning to see convergence, or vertical integration, as the path to growth, Panelists from Johns Hopkins Institutions, Buchanan Ingersoll & Rooney PC and Grant Thornton LLP share their experience.
The Retirement Landscape: Technical and Legal UpdateBPAS
The DoL’s proposed fiduciary regulation is the most controversial ERISA initiative since the enactment of the statute in 1974. If adopted as proposed, the regulation will have significant impact on financial institutions selling products to IRAs and 401(k) plans. The proposed changes would essentially open up the $7 trillion IRA market to ERISA, impacting the sale of investment products, from mutual funds to variable annuities, to IRAs. The proposal would also change the definition of an “advice fiduciary,” making it easier for the DoL to assert claims against persons or entities selling investment products or gathering assets.
In this session, we’ll discuss the impact of the DoL proposal for your business, from the stand-point of what needs to be changed to make the proposal “workable” and what you’ll need to do to comply if the proposal is adopted without change. Specifically, this session will focus on:
Changes to the definition of Investment Advice Fiduciary
Fiduciary status “carve-outs” for sales presentations
The new Best Interest Contract Exemption for IRAs
Changes to PTE 84-24 and other Exemptions
Guest Speaker: Steve Saxon, Principal, Groom Law Group
Real Estate Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
REITS are finding that while online shopping is active, their real estate holdings — stores and malls — continue to draw actual shoppers. Most sales still take place in brick-and-mortar, with technology shaping retail and real estate success.
For digital media companies, effective cybersecurity programs a mustGrant Thornton LLP
In digital media trust is everything, without it your business model doesn’t work. Cybersecurity can be a key component, ensuring the integrity of your services. Check out this brief guide to securing your data.
Dodd-Frank's Impact on Regulatory ReportingHEXANIKA
We previously analyzed how Dodd-Frank and how the new regulations have impacted large banks as well as midsize and small banks. This time, we will look at how the law meant to address one issue (avoid a financial meltdown similar to 2008) might have created other challenges for banks – the most important one that of regulatory reporting:
With these key best practices, you can create strong ERP governance that will help you use your platform effectively, with an increased focus on the strategic objectives of your business.
Learn more - http://gt-us.co/1NJKpfZ
My books- Learning to Go https://gumroad.com/l/learn2go & The 30 Goals Challenge for Teachers http://amazon.com/The-Goals-Challenge-Teachers-Transform/dp/0415735343
Resources at http://shellyterrell.com/games
Keynote address (Feb, 2016) to the educators in the Fort Nelson school district. We all know that we cannot teach a child without a concection... without a relationship. In the hustle and bustle of our jobs as educators, we often forget our why, the reason we got into education, of trying to make a difference with kids. In this talk, 6 Keys to Connecting are shared and discussed with the challenge of creating a more positive climate and better connections with kids in our classrooms, schools, and organizations.
With the explosion of the maker movement, schools are beginning to embrace creativity. However, what does this mean for assessment? Should we assess the creative process? Should we assess the finished product? Does assessing creativity actually make kids more risk-averse? In this workshop we explore what it means to assess both the creative process and the creative product without leading to risk aversion.
Tightening pressure transforms the landscape: The state of asset managementGrant Thornton LLP
After years of growth, asset managers face a number of challenges. Here, we examine these challenges and provide insight into the state of the asset management industry.
Becoming a better leader is something that can help a whole company prosper. But having bad leaders can derail an entire group. Find out if you're one of the five types of leaders who derail (and ways to correct that).
5 Creative Principles for Remarkable PresentationsMichelle Mazur
Every time I ask the question “what’s the most difficult part of writing a speech?” the answer is always the same. STARTING.
Writing a presentation is inherently a creative process. It’s no different than painting a picture, choreographing a ballet, or writing a novel. Every artist (and speakers ARE artists) starts with a blank canvas, page, or PowerPoint slide.
To write a remarkable presentation, you’ve got to get your creative juices flowing. You’re not writing just another speech – a remarkable presentation is an artistic creation.
Step away from the computer and take a more creative approach to writing your speech.
So let’s get to the work of creating with these five creative principles for remarkable presentations, shall we?
Everything We Wish We Knew About Twitter When We Started
A look at the basics of getting started with Twitter, how to grow your following and your engagement, and how to get the most value and fun out of a truly amazing network.
Development and Engagement in the Age of Social Media Paul Brown
Originally presented to the professional staff at the University of Dayton in January of 2016. Reviews aspects of college student development online and how to engage college students.
How To Generate Your First 20,000 Followers On InstagramRoss Simmonds
Be sure to check out: RossSimmonds.com for more information on Instagram!
Want to grow your Instagram following quickly? In this guide, I describe some of the tactics being used by brands all over the world and personal accounts to build their following.
Stop Selling Start Helping! Learn from Atlassian. Focus on the clients. What do they really need? Find out and help them.
How can you add even more value? Make the client look brilliant and they will love you forever.
Resourcefulness, creativity can help further your nonprofit's missionGrant Thornton LLP
If there’s one lesson that nonprofit organizations have learned in recent years, it’s that resources are finite and must be allocated prudently. How not-for-profits must quickly adapt to find new and creative ways to respond. See more in our State of not-for-profit industry 2014: http://gt-us.co/StateofNFP2014
Data breaches and theft of user information can do crippling damage to a digital media company. Creating an effective cybersecurity program is a critical step.
As the volume of electronic medical data has grown, so has the number of third-party custodians who handle it. Organizations increasingly rely on third parties for infrastructure, managed applications and data management. Navigating the changing rules governing these third parties
has become more complex. The risk of these relationships is significant: Third parties are responsible for almost half of all data breaches. Compounding these challenges are new federal requirements for managing electronic protected health information. Important changes that take effect Sept. 23, 2013 in the Health Insurance Portability and Accountability Act (HIPAA) Omnibus Rule broaden the definition of a business associate, set new limits on how data may be used, redefine what constitutes a breach and establish new civil penalties for violations. Failing to properly assess risks inherent in these relationships and inadequately implementing monitoring controls to address the risk of third-party relationships can be costly in terms of potential penalties and damage to an organization’s reputation.
Reserves planning: Determining the appropriate level of reserves for your org...Grant Thornton LLP
Maintaining adequate reserves is essential to establishing financial stability. These reserves provide a cushion to deal with operating deficits that may arise due to unexpected events, economic uncertainties, lean funding periods or opportunities for strategic investment. This presentation offers Grant Thornton’s latest thinking on how to establish appropriate reserves levels and our methodology for developing a sophisticated and robust risk-based approach to establishing a reserves policy within your organization.
The Economic Impact of Female EntrepreneursKyle Lacy
In 1999, Babson College’s Diana Project published its seminal report on the state of venture capital investments in female entrepreneurs. This report set out to examine why fewer than 5% of all ventures receiving equity financing had women on their executive teams. While antiquated logic might have left you to quickly surmise that female entrepreneurs were neither prepared nor motivated to found high-potential businesses and as a result, were not good candidates for venture capital investors, the Diana Project report actually found stark evidence to the contrary.
Women indeed had the skills, expertise and experience required to lead high-growth ventures, yet, despite their preparedness and qualifications, were consistently left behind.
Fast forward to the second iteration of the report published last year. Unlike the bleak picture the original report drew, time shifted the landscape in the favor of female leaders. While there is still much progress to be made, the 2014 report uncovered immense growth. In fact, data from the report showed that between 2011 and 2013 more than 15% of the companies receiving venture capital investment had a woman on the executive team, compared with just 5% in 1999, proving that given the chance and access to the right networks, women can command equity financing to grow their businesses. And, to further show that women can and will succeed when given the opportunity, First Round Capital discovered just this week that their investments with a female founder performed 63% better than those with all-male founding teams.
Creating Sticky Learning To Combat Our Illusion Of KnowingJeff Hurt
As adults, we are rather lazy learners.
Much of what we hold as fact regarding learning is actually illusion. We waste a lot of effort, time and resources with common-sense accepted educational practices that are rooted in intuition, tradition and myth.
The most effective learning strategies and education programming are counter-intuitive. We need to build new bridges between our education offerings and the learning research in order to increase our participants’ ROI. We need to develop a deeper understanding of the why and how to create learning opportunities that stick.
The famous educational philosopher, John Dewey, stated “We do not learn from experience, we learn from reflecting on experience.’ Maker education involves hands-on and experiential activities. Learning can occur through the act of making but having learners reflect on their making experiences increases the likelihood of learning. It is not left to chance.
Running head LEGAL UNDERPINNINGS OF BUSINESS LAW1LEGAL UNDER.docxcharisellington63520
Running head: LEGAL UNDERPINNINGS OF BUSINESS LAW 1
LEGAL UNDERPINNINGS OF BUSINESS LAW 8
BUSINESS LAW
Name
Institution
Date
Constitutional and legal underpinnings of business law
The 14th Amendment still stands as one of the most historically important building blocks to the history of the United States democracy. Along with the other two Reconstruction Amendments, it continues to uphold the nation’s promise that everyone is created equally under the law despite race, gender, nationality or orientation. The uniqueness of the 14th Amendment is defined in the United States Constitution and it still continues to be an influence on the history and growth of this great nation.
Section 1 of the 14th amendment that addresses Regulation of Business Enterprises: Rates, Charges, and Conditions of service which links businesses with public interest. In endeavoring to measure the impact of the due process clause upon efforts by the States to control the charges exacted by various businesses for their services. Since the inception of the 14th amendment the united states supreme court has devoted itself in the examination of two questions: (1) whether the clause precluded that kind of regulation of certain types of business, and (2) the nature of the restraint, if any, which this clause imposed on state control of rates in the case of businesses as to which such control existed.
In the case that a business was ‘‘affected with a public interest’’, control of its prices, rates, or conditions of service was viewed as an unconstitutional deprivation of liberty and property without due process of law. During the period of its application, however, this standard, ‘‘business affected with a public interest,’’ never acquired any precise meaning.
This part of the amendment limits business as it seeks to control any enterprise .For example in a profession such as a ticket reseller. They came to hold such a peculiar relation to the public that this was superimposed upon them. The owner by devoting his business to the public use, in effect grants the public an interest in that use and subjects himself to public regulation to the extent of that interest although the property continues to belong to its private owner and to be entitled to protection accordingly .Fixing the price at which tickets are resoled limited competition as high capital investors still have to resell them at the same price as the low capital investors.
Capital gains
From the article, the planning opportunities that could be beneficial are;
For individuals, the best strategy would be factoring in the tax implications of the assets to be sold so that one may ascertain whether the move would be appropriate ort not i.e. Convert them to ordinary income or leave them on the long term capital gain basis.
Also, the individuals seeking to sell their assets should be clear on whether they are under the corporate sale or not. This is because if the asset sale is under a corporation it woul.
Real Estate Partnerships and the Looming Tax Shelter ThreatCBIZ, Inc.
Many touted the tax reform legislation known as the TCJA as the most significant change to the Internal Revenue Code (IRC) since the Tax Reform Act of 1986. In the roughly 14 months since the passage of the TCJA, taxpayers have been eager to capitalize on the tax cuts. The changes have left tax practitioners attempting to keep pace while trying to decipher hundreds of pages of proposed and final tax regulations.
Off Payroll Working In Private Sector | Makesworth Accountants in HarrowMakesworth Accountants
New tax rules for individuals working via their own companies for medium or large business. From 6 April 2020, new tax rules are proposed for individuals who provide their personal services via an ‘intermediary’ to medium or large business. An intermediary may be another individual, a partnership, an unincorporated association or a company. The most common structure is a worker providing their services via their own company (PSC) which is the term used in this letter to summarise the rules which will apply to all intermediaries. Similar rules were introduced in 2017 for public sector organisations receiving services from PSCs. The 2020 rules will use the 2017 rules as a starting point which means, in practical terms, that the principles have already been decided but some aspects of the detailed operation of the rules will be decided in a consultation process. Draft legislation has been published which will, subject to consultation, be included in the next Finance Bill.
Anyone who is a Buy-to-Let investor holding property personally should consider this possible scenario. It might reduce tax on rental income as well as achieve a CGT free uplift in base cost, while allowing income to be accessed free of tax. This possible solution which uses a LLP might also provide IHT efficiency.
The IRS is pursing all manner of estate planning transactions involving family-controlled entities ("FCEs") and now has gone straight to the heart of the matter - valuation.
GT Events and Program Guide is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
GT Events and Program Guide is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
GT Events & Program Guide: ForwardThinking October/November 2017Grant Thornton LLP
ForwardThinking is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
Banking Industry Success: Build, Transform and Protect Value into 2020Grant Thornton LLP
Banking leaders say their focus on customer service will double between now and 2020, becoming their No. 1 priority in an increasingly competitive environment.
GT Events & Program Guide: ForwardThinking August/September 2017Grant Thornton LLP
ForwardThinking is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
ForwardThinking is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
The Future of Growth and Industries Webcast Series: Trends to watch for 2020Grant Thornton LLP
An analysis of future challenges across industry based on recent research. The presentation features technology disruption and internationalism as key themes.
ForwardThinking is a look ahead at the latest knowledge and insights available from Grant Thornton LLP. It includes a collection of our research, thought leadership and a schedule of upcoming webcasts and events.
The Future of Industry: Sector Convergence & 2017 OutlookGrant Thornton LLP
What is the future of industries? How should we respond to the opportunities and challenges presented by this disruption? Every industry is being disrupted by fast-paced change on many fronts. In this deck, Grant Thornton industry leaders explore cross-industry issues and potential solutions to support your business in this ever-changing world.
Leaders everywhere face increasing risks for their organizations. But not all risks are created equal. And not all organizations have the same ability to measure, manage or mitigate these risks.
Since 2013, pass-through owners have faced a potentially higher tax rate (39.6%) on their business income than their C corporation competitors (35%). This rate disparity puts them at a competitive disadvantage and hinders growth. http://gt-us.co/1SPWvqZ Learn more about how a business equivalency rate ensures all businesses are taxed equally.
3 hard facts shaping higher education thinking and behaviorGrant Thornton LLP
Expansion in tuition, enrollment, faculty, buildings, and everything else ― is fast becoming a thing of the past. Institutions will have to carefully pick initiatives, making clear choices about what to do and, most significantly, what not to do. Download 2016 State of higher education >> http://gt-us.co/1UbUF56
Imagine … internal auditors identifying risks + opportunities from data. Internal auditors can + need to grasp this opportunity to transform their role and industry. More >> grantthornton.com/data-analytics
An industrial approach to risk and control self-assessmentsGrant Thornton LLP
Derive more value from your risk and control self-assessment process, and integrate your organization’s overall operational risk management process to comply with Dodd Frank and other legislation. We specialize in working with clients to help identify, remediate and resolve assessment gaps so they efficiently meet or exceed regulatory requirements.
Taking the road to advanced approaches and heightened standards in risk manag...Grant Thornton LLP
Develop and execute a roadmap to meet rising regulatory and stakeholder expectations. Banks of all sizes are required to build sophisticated analytical risk management capabilities in compliance with Dodd-Frank and other legislation making a priority of optimizing the deployment of capital and infusing objectivity into its allocation.
Keys to extract value from the data analytics life cycleGrant Thornton LLP
Regulatory mandates driving transparency and financial objectives requiring accurate understanding of customer needs have heightened the importance of data analytics to unprecedented levels making it a critical element of doing business.
CCAR & DFAST: How to incorporate stress testing into banking operations + str...Grant Thornton LLP
Banks are integrating elements of regulatory stress testing into their everyday business processes and strategic planning exercises, and optimizing enterprise risk management in the process. What does enterprise wide stress testing mean for a financial institution? What are the impacts and implications to a financial institution?
Slack (or Teams) Automation for Bonterra Impact Management (fka Social Soluti...Jeffrey Haguewood
Sidekick Solutions uses Bonterra Impact Management (fka Social Solutions Apricot) and automation solutions to integrate data for business workflows.
We believe integration and automation are essential to user experience and the promise of efficient work through technology. Automation is the critical ingredient to realizing that full vision. We develop integration products and services for Bonterra Case Management software to support the deployment of automations for a variety of use cases.
This video focuses on the notifications, alerts, and approval requests using Slack for Bonterra Impact Management. The solutions covered in this webinar can also be deployed for Microsoft Teams.
Interested in deploying notification automations for Bonterra Impact Management? Contact us at sales@sidekicksolutionsllc.com to discuss next steps.
LF Energy Webinar: Electrical Grid Modelling and Simulation Through PowSyBl -...DanBrown980551
Do you want to learn how to model and simulate an electrical network from scratch in under an hour?
Then welcome to this PowSyBl workshop, hosted by Rte, the French Transmission System Operator (TSO)!
During the webinar, you will discover the PowSyBl ecosystem as well as handle and study an electrical network through an interactive Python notebook.
PowSyBl is an open source project hosted by LF Energy, which offers a comprehensive set of features for electrical grid modelling and simulation. Among other advanced features, PowSyBl provides:
- A fully editable and extendable library for grid component modelling;
- Visualization tools to display your network;
- Grid simulation tools, such as power flows, security analyses (with or without remedial actions) and sensitivity analyses;
The framework is mostly written in Java, with a Python binding so that Python developers can access PowSyBl functionalities as well.
What you will learn during the webinar:
- For beginners: discover PowSyBl's functionalities through a quick general presentation and the notebook, without needing any expert coding skills;
- For advanced developers: master the skills to efficiently apply PowSyBl functionalities to your real-world scenarios.
UiPath Test Automation using UiPath Test Suite series, part 3DianaGray10
Welcome to UiPath Test Automation using UiPath Test Suite series part 3. In this session, we will cover desktop automation along with UI automation.
Topics covered:
UI automation Introduction,
UI automation Sample
Desktop automation flow
Pradeep Chinnala, Senior Consultant Automation Developer @WonderBotz and UiPath MVP
Deepak Rai, Automation Practice Lead, Boundaryless Group and UiPath MVP
Dev Dives: Train smarter, not harder – active learning and UiPath LLMs for do...UiPathCommunity
💥 Speed, accuracy, and scaling – discover the superpowers of GenAI in action with UiPath Document Understanding and Communications Mining™:
See how to accelerate model training and optimize model performance with active learning
Learn about the latest enhancements to out-of-the-box document processing – with little to no training required
Get an exclusive demo of the new family of UiPath LLMs – GenAI models specialized for processing different types of documents and messages
This is a hands-on session specifically designed for automation developers and AI enthusiasts seeking to enhance their knowledge in leveraging the latest intelligent document processing capabilities offered by UiPath.
Speakers:
👨🏫 Andras Palfi, Senior Product Manager, UiPath
👩🏫 Lenka Dulovicova, Product Program Manager, UiPath
Key Trends Shaping the Future of Infrastructure.pdfCheryl Hung
Keynote at DIGIT West Expo, Glasgow on 29 May 2024.
Cheryl Hung, ochery.com
Sr Director, Infrastructure Ecosystem, Arm.
The key trends across hardware, cloud and open-source; exploring how these areas are likely to mature and develop over the short and long-term, and then considering how organisations can position themselves to adapt and thrive.
DevOps and Testing slides at DASA ConnectKari Kakkonen
My and Rik Marselis slides at 30.5.2024 DASA Connect conference. We discuss about what is testing, then what is agile testing and finally what is Testing in DevOps. Finally we had lovely workshop with the participants trying to find out different ways to think about quality and testing in different parts of the DevOps infinity loop.
Builder.ai Founder Sachin Dev Duggal's Strategic Approach to Create an Innova...Ramesh Iyer
In today's fast-changing business world, Companies that adapt and embrace new ideas often need help to keep up with the competition. However, fostering a culture of innovation takes much work. It takes vision, leadership and willingness to take risks in the right proportion. Sachin Dev Duggal, co-founder of Builder.ai, has perfected the art of this balance, creating a company culture where creativity and growth are nurtured at each stage.
Transcript: Selling digital books in 2024: Insights from industry leaders - T...BookNet Canada
The publishing industry has been selling digital audiobooks and ebooks for over a decade and has found its groove. What’s changed? What has stayed the same? Where do we go from here? Join a group of leading sales peers from across the industry for a conversation about the lessons learned since the popularization of digital books, best practices, digital book supply chain management, and more.
Link to video recording: https://bnctechforum.ca/sessions/selling-digital-books-in-2024-insights-from-industry-leaders/
Presented by BookNet Canada on May 28, 2024, with support from the Department of Canadian Heritage.
UiPath Test Automation using UiPath Test Suite series, part 4DianaGray10
Welcome to UiPath Test Automation using UiPath Test Suite series part 4. In this session, we will cover Test Manager overview along with SAP heatmap.
The UiPath Test Manager overview with SAP heatmap webinar offers a concise yet comprehensive exploration of the role of a Test Manager within SAP environments, coupled with the utilization of heatmaps for effective testing strategies.
Participants will gain insights into the responsibilities, challenges, and best practices associated with test management in SAP projects. Additionally, the webinar delves into the significance of heatmaps as a visual aid for identifying testing priorities, areas of risk, and resource allocation within SAP landscapes. Through this session, attendees can expect to enhance their understanding of test management principles while learning practical approaches to optimize testing processes in SAP environments using heatmap visualization techniques
What will you get from this session?
1. Insights into SAP testing best practices
2. Heatmap utilization for testing
3. Optimization of testing processes
4. Demo
Topics covered:
Execution from the test manager
Orchestrator execution result
Defect reporting
SAP heatmap example with demo
Speaker:
Deepak Rai, Automation Practice Lead, Boundaryless Group and UiPath MVP
Generating a custom Ruby SDK for your web service or Rails API using Smithyg2nightmarescribd
Have you ever wanted a Ruby client API to communicate with your web service? Smithy is a protocol-agnostic language for defining services and SDKs. Smithy Ruby is an implementation of Smithy that generates a Ruby SDK using a Smithy model. In this talk, we will explore Smithy and Smithy Ruby to learn how to generate custom feature-rich SDKs that can communicate with any web service, such as a Rails JSON API.
Generating a custom Ruby SDK for your web service or Rails API using Smithy
TIP on Tax: New rules may ease burden for small shareholders in tech acquisitions
1. TIP on Tax:
New rules may ease burden for small
shareholders in tech acquisitions
This is the fourth installment of TIP on Tax, a series
from Grant Thornton LLP’s Technology Industry
Practice (TIP). The series introduces key tax issues for
dynamic technology companies.
In our first article, we explored strategies for managing
net operating losses (NOLs) generated in the startup
phase. Our second article offered insights into the
effective use of NOLs resulting from acquisitions of
loss-making businesses. The third article addressed
accounting for NOLs. This article focuses on new rules
put out by the IRS that could ease compliance burdens
for small shareholders of those loss-making businesses.
Introduction
The super-hot tech M&A market can be good news
for smaller technology companies seeking to be
acquired and — perhaps more importantly — for
their shareholders. Yet many of those companies
remain in a tax loss position following years spent in
not-yet-profitable R&D, or trying — often at a loss
— to expand business profitability. Section 382 of the
Internal Revenue Code generally limits the amount
of NOLs a new buyer can use after acquisition, to
prevent so-called “loss trafficking.”
Beginning in 1986, the IRS and Treasury Department
began putting into place an extremely complicated
set of rules under section 382 to prevent such loss
trafficking. One major fallout from those rules is a high
degree of complexity and compliance burden, coupled
with a system that might imply an ownership change
has occurred (limiting the use of NOLs) when, to a
layperson, it doesn’t appear there was a loss trafficking
transaction. Fortunately, new IRS regulations are
trying to address some of those concerns.
Loss limitations, generally
When a technology company undergoes an ownership
change, its ability to use its NOLs becomes limited.
An ownership change occurs when one or more 5%
shareholders increase their ownership, in aggregate,
by more than 50 percentage points over a three-year
period. Congress decided to create this limitation to
prevent profitable companies from purchasing those
in a loss position purely to use those losses to offset
future profits.
Greg Fairbanks, Senior Manager and Corporate Tax Specialist, Grant Thornton LLP
Section 382 of the Internal Revenue Code generally limits the
amount of NOLs a new buyer can use after acquisition, to prevent
so-called “loss trafficking.”
2. 2
Aggregation and segregation
Under previous rules, direct and indirect small
shareholders (those owning less than 5% of the target
loss company) were aggregated and treated as a 5%
shareholder (called a “public group,” even if these
were shareholders of a private company) upon starting
a section 382 analysis. The rules then required the
creation of an additional public group every time a
person who owned 5% or more of the corporation
sold stock to small shareholders (i.e., less than 5%).
These aggregation and segregation rules caused
problems for many shareholders, especially when
stock was frequently purchased and sold. And the
rules often caused or hastened ownership changes
when there was no intent or motive of loss trafficking.
In October 2013, the IRS and Treasury Department
changed their regulations to address the unintended
consequences of these complex rules by creating three
exceptions to the general rule of segregation for some
transactions involving a loss corporation and 5%
shareholders:
• Secondary transfer exception
• Small redemption exception
• General exception to segregation rules for 5%
entities and shareholders
Secondary transfer exception
Under this exception, the segregation rules don’t
apply with respect to transfers of loss corporation
stock to small shareholders from 5% shareholders or
entities. They also wouldn’t apply to transfers of 5%
entity stock to small shareholders.
Small redemption exception
Under this exception, the loss corporation doesn’t
segregate into a new direct public group redemptions
of stock that are “small” and fall within rules
governing this exception. The rules are a mirror of the
small issuance exceptions and exempt from segregation
up to 10%, by class or by fair market value, of the
stock redeemed within a tax year.
Suppose a corporation was owned 100% by small
shareholders, and the company undertook a tender
offer to redeem 10% of the shares. Under the old
rules, the 10% would be segregated from the 90%
that continue as shareholders. After the redemption,
the continuing shareholders own 100%, with a 10%
cumulative shift occurring. Under the new rules,
no such segregation takes place and the company is
treated as owned 100% by small shareholders both
immediately before and after the tender offer, resulting
in a 0% shift.
TIP on Tax: New rules may ease burden for small shareholders in tech acquisitions
Example:
LossCo is owned 20% by X and 80% by small
shareholders aggregated as a public group. On
successive dates within a three-year period, X sells
its stock to small shareholders, and Y then purchases
20% from the public. Under the old law, X’s sale
would create a new public group with 20% ownership
of LossCo, and the historic public owning 80%. The
purchase by Y comes pro rata from both groups, with
the end result being Y owning 20%, historic public
64%, and new public (from X’s sale) 16%. The total
ownership shift is 36% because both Y and the new
public are new, non-historic shareholders. Under the
new law, X’s sale goes back to the historic public and
Y buys from such historic public. The end result is that
Y owns 20% and the historic public 80%, for a total
ownership shift of only 20%.
3. General exception to segregation rules for
5% entities and shareholders
The final regulations also provide relief for indirect
shifts for first-tier entities that own 5–10% of a
corporation’s stock. Prior to the new law, corporations
were obligated to look through and track indirect
shifts for any entity that owned 5% or more of the
corporation’s stock. That means indirect issuances
and redemptions could create indirect shifts. This
also resulted in a high compliance burden for the
corporation, as it was difficult to obtain all the
information necessary to do such an analysis. The new
law prevents such segregation from taking place for
entities that own 10% or less, mitigating some of this
complexity.
TIP on Tax: New rules may ease burden for small shareholders in tech acquisitions
Note: In the previous example, if the LLC owned
15%, the new regulation would not apply and the
corporation would be in the same quandary as under
prior law.
Simpler application
These new regulations are meant to make life a little
easier for small shareholders and 5% shareholders
of loss corporations, and they’re here just in time.
For many tech companies that have gone through
initial funding and subsequent investment stages,
it’s entirely possible to have many different public
groups. And even if the company is still privately
held, a thriving secondary market for shares can
result in administrative burdens for those remaining
shareholders in the event of an acquisition.
The final rules are effective as of Oct. 22, 2013, and
may be permissively applied to dates before then, so
long as application of the final rules doesn’t result
in an ownership change occurring before Oct. 22.
The final regulations may not be applied to any date
on or before the date of an ownership change that
occurred before Oct. 22.
Though improved, these regulations are still
complicated, and there are myriad issues to consider.
Companies should consider consulting with tax
professionals to avoid unexpected surprises.
3
Example:
A corporation is owned 10% by a limited liability
company (LLC) that has historically issued and
redeemed membership interests. However, the LLC,
which has historically been reluctant to share private
owner information, has no legal obligation to share
this information with the corporation. Prior to the new
law, the corporation was obligated to track and take
into account the effect of all those indirect issuances
and redemptions. Practically, this was an almost
impossible task that could result in potentially negative
results. The new law prevents such segregation
events from taking place, thereby obviating the need
to obtain such information.
Contacts
Paul Howell
Partner and National Technology
Industry Tax Leader
T 214.561.2314
E paul.howell@us.gt.com
Greg Fairbanks
Senior Manager and
Corporate Tax Specialist
T 202-521-1503
E greg.fairbanks@us.gt.com