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Forum Program



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

The 2018 program will be announced in Spring 2018, but, among other items, it is expected to include:

The Impact of TCJA on Closely Held Business Planning and Structuring, Including:

Issues and planning options pertaining to the §199A deduction

• Structuring compensation arrangements to maximize the §199A 20% flow-through deduction

• Personal service businesses and §199A: what they are and structuring options to obtain a deduction

• When switching to C corporation status may make sense

• Structuring flow-through entity debt arrangements to avoid the new 30% interest deduction limitation

• Navigating the new three-year carried interest income recharacterization

• Understanding the new net operating loss carryover limitations

• The elimination of §708(b)(1)(B) terminations and its impact on succession planning

• Necessary revisions to tax distribution provisions

Forum XXXII’s Top Ten – 2018’s Most Significant Structuring Techniques and Foot Faults


Thursday Evening Networking Dinners (6:30 PM)

Boston — EVOO (October 18)
Chicago — Beatrix (Streeterville) (October 25)
Washington, D.C. — Kora Restaurant (November 8)
Nashville — Jack Daniel’s (November 15)
San Diego — Chianti (December 6)

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)


Forum XXXII’s Top Ten – More on 2018’s Most Significant Structuring Techniques and Foot Faults

Hot Partnership and LLC Topics for 2018

CCA 201805013 and when activities can be aggregated for §465 at-risk purposes
Who may or may not qualify for the expanded use of the cash method of accounting
Examination of the final and newly proposed partnership-level audit regulations
A potpourri of recent partnership and LLC developments

Hot S Corporation Topics for 2018

S to C conversions and the new §1371 PTTP rules for distributions
Using ESBTs to maximize the §199A deduction
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.