Discounted Redemptions: Developments with Sub T and Electric Utility Cooperatives

Date: Thursday, November 6, 2008
Time: 11:00 AM ET / 10:00 AM CT / 09:00 AM MT / 08:00 AM PT [Prevailing Time]
Presenters: Dan Schultz , CPA, Cooperative Consulting, LLC, Bill Miller, CPA , tax partner, Bolinger, Segars, Gilbert & Moss, LLP
Moderator:
Learning Objectives:
To discuss recently published IRS private letter rulings on the issue of discounted equity redemption plans and to apply the principles of these published rulings to discounted equity redemption plans of both Sub-chapter T and electric utility cooperatives.
Field of Study: Taxes
Program Level: Intermediate
CPE Credit: 1 Credit Hour
Delivery Method: Group Internet-based
Prerequisite(s): No advanced preparation or prerequisites are required for this course.

Course Description

This CLN will (1) provide an overview of redeeming patronage capital on a discounted basis, (2) provide an overview of the common reasons cooperatives redeem patronage capital at a discount, (3) discuss and compare the private letter rulings issued by the IRS from 2006 through 2008 to electric cooperatives, (4) discuss longstanding IRS position for Subchapter T cooperatives and compare to the Goldkist 11th circuit decision, (5) walk through the steps for implementing a discounted patronage capital redemption plan based on published IRS rulings, and (6) walk through a common example and the impact to both the Cooperative and the patrons.

Presenter and Moderator Bios

Presenter: Dan Schultz , CPA, Cooperative Consulting, LLC

Bill Miller, CPA is a tax partner at the accounting firm of Bolinger, Segars, Gilbert and Moss in Lubbock, Texas. He began his career with the firm in 1992 and holds an accounting degree from the University of Texas. Bill is in charge of the firm's utility tax practice, which provides tax and consulting services to the firm's audit clients with an emphasis on the firm's exempt and non-exempt electric, telephone and agricultural cooperatives and related subsidiary companies. His responsibilities include tax return preparation, tax planning, recommendations for entity selection and organizational structure and recommendations for structuring plans to allocate and redeem patronage capital. Bill and his wife Kim, along with their two year old daughter, reside in Lubbock, Texas. Dan Schultz is a CPA with Cooperative Consulting, LLP and before retiring as a tax partner in 2004 had served as National Director of tax services to cooperatives for PricewaterhouseCoopers. He spent thirty-four years in the Minneapolis and St. Louis offices of PWC and has been working with cooperatives for over thirty years. His co-op tax experience includes due diligence and tax planning in connection with several major co-op mergers and LLC joint ventures, representing co-ops in handling IRS examinations and appeals, planning large acquisition and financing transactions and helping clients develop and restructure patronage programs. Dan's many professional activities include involvement in several reporting subcommittees of the Legal, Tax and Accounting Committee of the National Council of Farmer Cooperatives and he serves as a member of the Tax committee for the National Society of Accountants for Cooperatives (NSAC). He is also a member of the National Cooperative Business Association. He graduated from the University of Minnesota and is a member of several professional accounting and community service organizations.

Presenter: Bill Miller, CPA , tax partner, Bolinger, Segars, Gilbert & Moss, LLP

Cost
$56.00 for NSAC Members / $70.00 for Non-Members

Delivery System

  • All programs are delivered using the Zoom platform.
  • Confirmations will include log-in instructions.
  • Participants are able to participate using any device with an Internet connect (if the device does not have speakers, the participant can also dial-in) or they can participate with audio only by dialing in.
  • All registrants will receive a link to the CLN’s recording by email within 48 business hours of event’s conclusion.
  • There will be assistance available to help with technical and connectivity issues up to 10 minutes prior to the start of the presentation.

Registration

All registration is done on-line and each guest must provide their name and email address to participate. All NSAC members may register for free. Non-members may register for a nominal fee.

Refund Policy

NSAC will not issue refunds for CLNs. If a registrant is unable to participate in the CLN and provides notification to info@nsacoop.org 48 hours prior to the session, a credit will be provided for a future CLN. Alert the NSAC staff member monitoring the CLN if technical difficulties are encountered and technical support will be provided to eliminate problems with future CLNs.

Additional Information

Live participation is required for CPE credit and polling questions must be answered to document your active participation. All registrants will receive an email following the session with links to the slides and/or handouts, and a link to the CLN recording (unless otherwise stated). If you are unable to participate in the live session, you can still watch the recorded session, but you will not be eligible for CPE credits. Those eligible for credits will receive their certificate by email with 7 business days.

For more information regarding NSAC CLNs or administrative policies such as complaint and refund, contact the NSAC Headquarters, 7946 Clyo Road, Suite A, Centerville, OH 45459, 937-222-6707, or info@nsacoop.org.

What is NSAC's Cooperative Learning Network?
The NSAC Cooperative Learning Network is a live, interactive webinar, and you can attend from any location with internet and/or telephone access. NSAC members can attend an unlimited number of CLNs at no charge!

Each Cooperative Learning Network will have one or more speakers who are recognized experts on the topic. CLNs typically include a Q&A session where participants can ask questions live or by chat. No advance preparation or prerequisites are required, unless otherwise stated in the course information. Attendees are able to download copies of the slides and/or handouts and are provided a link to view the recording (unless the description states the session will not be recorded). These tools help continue your learning experience after the session.

CPE Credits
The National Society of Accountants for Cooperatives (NSAC) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor (#103068) of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Delivery Method: Group-Internet Based.

Why NSAC Cooperative Learning Networks?

Fast.
No wasted time. Get right to the heart of the matter in a course designed to easily fit into your busy schedule.

Convenient.
No travel. No time out of the office. Listen and follow along from the comfort and convenience of your desk, device or conference room.

Easy.
A device with an Internet connection is all you need. If your device does not have sound capabilities, the ability to dial in from a telephone is available.

Ideal for multiple attendees.
Use a speakerphone and projector/monitor and invite as many people as you want to participate - at no extra cost to you.

Affordable.
NSAC Cooperative Learning Networks are free for members and available to non members at a fraction of the cost of travel and attendance fees for other high-priced conferences or seminars.