I Setting the Stage For Planning and Compliance – Choosing the Optimal Entity
- Deciding among partnerships, LLCs, S corporations and C corporations – the §199A deduction, computation of basis, permitted owners, permissive allocations, distributions, basis adjustments, amounts at risk, §1202 gain exclusion and §1045 rollovers
- Structuring entities to minimize self-employment tax exposure
II Structuring the Flow-Through Entity
- Using qualified S corporation subsidiaries and single-member LLCs
- Structuring the admission of the service provider
- Utilizing partnerships and LLCs to solve S corporation structuring limitations
- Eliminating C and S corporation penalty taxes by utilizing partnerships and other mechanisms
- Using partnerships and LLCs in everyday business and investment transactions
III Partnership Operational Issues
- Partnership allocations made easy – how to structure and report partnership allocations of profits, losses and liabilities under the §704(b), §704(c) and §752 regulations
- The partnership §754 basis adjustment rules
- Understanding the partnership hot asset rules
- The ABCs of like-kind exchanges involving flow-through entities and dealing with the “cash-out” partner