2017 "Fundamentals of Flow-Through" Program 2017 Forum Hotel Information 2017 Forum 2017 "Fundamentals of Flow-Through" Registration 2017 "Fundamentals of Flow-Through" Testimonials 2017 "Fundamentals of Flow-Through" Faculty 2017 "Fundamentals of Flow-Through" General Information Email Questions 2017 Forum Registration 2017 Forum Testimonials 2017 Forum Faculty 2017 Forum General Information 2017 "Fundamentals of Flow-Through" Hotel Information Email Questions 2017 "Fundamentals of Flow-Through" 2017 Forum Program



Forum Program



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

Structuring Techniques for 2017 and Beyond A Day of Closely Held Business Planning

The impact of any recent legislation and legislative proposals on closely held business planning

Forum XXXI’s Top Ten – 2017’s most significant structuring techniques and foot faults (some of which may be covered on day two)

Discerning recourse vs. nonrecourse debt under the re-proposed §752 regulations

The temporary §752 regulations and ameliorating the impact of the end of “bottom guarantees”

Castigliola and Hardy’s impact on the §1402(a)(13) self-employment tax exclusion

Hidden traps and opportunities under the basis adjustment rules

Thinking outside the box to take advantage of §1031

Avoiding the related party minefields in §453 transactions


Evening One Networking Dinners (6:30 PM)

Nashville — Jack Daniel’s (September 18)
Boston — Salvatore’s (October 19)
Chicago — Mity Nice Grill (October 26)
Washington, D.C. — Portofino Restaurant (November 16)

San Diego — Chianti (December 7)

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



Day Two
8:00 AM to 4:00 PM (Lunch on your own 11:45-1:00)

Hot Partnership and LLC Topics for 2017

When gross income allocations may be required under §704(b)

The final §707 regulations nixing tax-free treatment of many debt-financed distributions relating to partnership formation transactions

Why and how to avoid a Rev. Rul. 99-5 deemed “asset purchase” transaction

Examination of partnership-level audit rule developments

A potpourri of recent partnership and LLC developments, including the FLP decision in Powell


Hot S Corporation Topics for 2017

What the Fourth Circuit’s affirmation of QinetiQ means for blown §83(b) elections, and whether anything in Austin changes the thought process

Obtaining basis step-ups for real estate owned by an S corporation

Inverting an S corporation to facilitate partnership taxation

A potpourri of recent S corporation developments

The faculty members will utilize 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 and by audience participation. Some of the topics may not be covered orally.