I Structuring Techniques for 2025 and Beyond – An In-Depth Look at Closely Held Business Planning
II Forum XXXIX’s Top Ten: 2025’s Most Significant Flow-Through Issues and Avoidance of Foot Faults
III Emerging Partnership and LLC Topics for 2025 and Beyond
- Where we stand with the extension of TCJA provisions and other legislative action impacting closely held businesses
- §1402(a)(13) developments, including Sorobon, Denham, LJW Ventures and Stelliam
- 2025’s §704(b)/§704(c)/§752 structuring issues and techniques
- Update on the application of Loper Bright (elimination of deference to Treasury regulations) to flow-through entities
- The impact of the final §752 regulations governing related-party debt allocations
- The status of the IRS attack on basis-shifting transactions, including Otay (if decided), and the ability to engage in everyday basis-shifting transactions as a result of the Treasury/IRS retreat
- The §1202 tool box for using the 100% capital gain exclusion, including the integration of §1202 and corporate reorganizations
- The controversial IRS §1031 drop-and-swap analysis in PLR 202450005 and PLR 202449007
- The pressure points in using an installment note to avoid boot in a §1031 exchange