Forum TWENTY-SECOND ANNUAL PARTNERSHIP, LLC & S CORPORATION TAX PLANNING FORUM

Day One
8:30 AM to 5:00 PM (Luncheon and Presentation 12:00-1:30)

Structuring Techniques for 2008 and Beyond—A Day of Closely Held Business Planning

Forum XXII’s Top Ten — 2008’s most significant structuring techniques and foot faults (some of which may be covered on day two)
Analyzing the new anti-mixing bowl regulations under §704(c)(1)(B) and §737
Examination of the newly finalized regulations on non-compensatory partnership options
Applying the at-risk rules to guarantees, capital contribution obligations and DROs, and an examination of Hubert III and expected new IRS guidance
CCA 200816030 — unraveling the confusion of eligibility to elect out of partnership taxation
PLR 200803004 and the federal income taxation of series LLCs
To purchase or redeem a partnership interest — that is the question!
Asset purchases vs. partnership interest purchases vs. capital contributions—understanding the timing differences for deductions under §704(b), §704(c) and §743(b)

 
Thursday Evening Brainstorming Dinner

Boston — Legal Sea Foods
Nashville — Ristorante Volare
Chicago — Ben Pao
Washington, D.C. — Old Ebbitt Grill
San Diego — EXY

Brainstorm with the faculty and fellow attendees
and spend an informal evening sharing war stories

 

Day Two
8:00 AM to 3:45 PM (Lunch on your own 11:45-12:45)

Hot Partnership and LLC Topics for 2008

Family limited partnership update, including the taxpayer victories in Mirowski and Holman
Profits interests vs. capital interests vs. options and the interaction with §409A
Quirks under the basis adjustment rules and an analysis of the expected mandatory basis reduction proposed regulations
Structuring tax distributions to avoid unintended economic results
A potpourri of recent partnership and LLC developments

Hot S Corporation Topics for 2008
Avoiding unexpected traps with S corporation installment sales
Capitalizing the S corporation, including examination of expected back-to-back loan proposed regulations and the newly finalized open account indebtedness regulations
Rev. Rul. 2008-22 and other developments in structuring the sale of S corporation stock to a grantor trust
A potpourri of recent S corporation developments
All faculty members are scheduled to participate in each session, utilizing extensive case studies and examples to illustrate the issues to be discussed. An analysis of recent legislation and the latest cases, regulations and rulings will be integrated into each session. Program content and timing are based upon the current status of the law and may be modified if warranted by new developments.