I. Structuring Techniques for 2026 and Beyond – An In-Depth Look at Closely Held Business Planning
II. Forum XL’s Top Ten: 2026’s Most Significant Flow-Through Issues and Avoidance of Foot Faults
III. Emerging Partnership and LLC Topics For 2026 and Beyond
- The impact of OBBBA guidance on flow-through entity structuring and tax reporting
- §1402(a)(13) SE tax developments and litigation status, including the important taxpayer victory in Sirius Solutions
- 2026’s §704(b)/§704(c)/§752 structuring issues and techniques
- Computing the eligible §1202 exclusion after incorporating a partnership and other §1202 developments
- Using a partnership division to effectuate a §1031 exchange
- The uncertain application of the §7701(o) economic substance doctrine and the conflict between the Liberty Global and Patel decisions
- Reporting transaction costs when buying or selling a business
- Negotiating the decision-making scope of the powers of the BBA partnership representative when representing the selling, incoming, or continuing partner