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Forum Program



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

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

Issues and planning options to maximize the 20% §199A deduction, including entity choice and structuring considerations

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

• Specified service businesses under §199A — what they are and structuring options to obtain a deduction

• When switching to C corporation status may make sense — factoring in §1202, §1045, and §531

• 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 Avoidance of 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 of 2018’s Most Significant Structuring Techniques and Avoidance of 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

The anticipated guidance on automatic waiver of certain S corporation inadvertent terminations and defective S elections
S to C conversions and the new §1371 PTTP rules for distributions of AAA
Can ESBTs be used to maximize the §199A deduction?
A potpourri of recent S corporation developments


The faculty members will utilize practical 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 day one's program may be covered on day two; some of day two's program may be covered on day one or may not be covered orally.