Portland Chapter Tackles Tax Shelters, Joint Ventures.

Don Longano of PricewaterhouseCoopers spoke to the Portland Chapter at its November 1999 meeting. His topic was corporate tax shelters, and his presentation included a discussion of current legislative proposals and their possible effect on traditional businesses, as well as recent judicial decisions, and the adequacy of current law protections. Mr. Longano reviewed proposals of the Joint Committee on Taxation staff designed to encourage disclosure and enhance penalties. He also discussed Treasury proposals which include a "Super Section 269" approach to the issue and Rep. Doggett's proposals (H.R. 2255). Mr. Longano said that, while action was unlikely in 1999, he expected the debate to continue into 2000.

Mr. Longano's presentation was preceded by a workshop on e-business and the use of emerging technologies in the tax department. Discussion focused on how to spend less time on compliance and more time on planning, and how to promote the tax department as a business partner with other areas of the company. Bob Filip of PricewaterhouseCoopers moderated the workshop.

The chapter's dinner speaker for the January 11 meeting was Matt Evans, Executive Director of Oregon Tax Research. Mr. Evans discussed challenges raced by the 1999 Oregon legislature and its responses to the issues. Mr. Evans concluded that he would judge the 1999 legislature more kindly that other observers because of his belief that spending was held below levels of prior years. Mr. Evans pointed out, however, that the future holds many challenges for the Oregon legislature. Spending pressures will continue as recently passed grassroots initiatives are required to be funded by state government. He expects that, because of recently imposed term limits on legislators, the need to educate newly elected officials on tax matters will become increasingly important to tax professionals.

Corporate use of LLCs was the topic at the February 2000 monthly meeting of the chapter. The guest speaker was David Culpepper of Miller, Nash, Wener, Hager & Carlsen, one of the Pacific Northwest's largest full-service law firms. Since "check the box" regulations cleared the way, LLCs have become popular vehicles for various types of corporate joint ventures. Mr. Culpepper compared features of the LLC to "S" corporations, partnerships, and "C" corporations and discussed various scenarios in which an LLC may be the preferred structure. The presentation included an explanation of certain pitfalls of the LLC structure, especially tax consequences of converting existing corporate subsidiaries into SMLLCs. Mr. Culpepper also reviewed Oregon's new universal conversion and merger statutes as they apply to LLCs.