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Forum Program

Seminar THIRTY-THIRD ANNUAL PARTNERSHIP, LLC & S CORPORATION TAX PLANNING FORUM



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

THE IMPACT OF TCJA ON CLOSELY HELD BUISNESS PLANNING AND STRUCTURING, INCLUDING:

  • Utilizing the concepts in the final §199A regulations to determine the most advantageous entity structures, compensation arrangements and business disposition choices, including:
    • SSTBs and non-SSTBs in the same RPE and fending off the SSTB “cliff” rule
    • What is a real property trade or business and the impact of Notice 2019-7
    • The UBIA traps and opportunities in common partnership and S corporation acquisition and disposition transactions
    • Restructuring a non-SSTB/SSTB S corporation enterprise for economic and tax maximization: a case study analyzing §199A, profits interests and SE tax considerations
  • Structuring businesses to minimize the impact of §163(j), including:
    • Measuring eligibility for the $25 million small business exemption and the impact of the “tax shelter” definition
    • Determining qualification for the real property trade or business exception and its application
    • The integration of self-rented property and §163(j) under the proposed regulations

FORUM XXXIII’s TOP TEN – PART ONE: 2019’s MOST SIGNIFICANT STRUCTURING TECHNIQUES AND AVOIDANCE OF FOOT FAULTS


Thursday Evening Networking Dinners (6:30 PM)

Boston — EVOO (September 19)
Nashville — Jack Daniel's (October 17)
Chicago — Mity Nice Grill (October 31)
Washington D.C. — Portofino Restaurant (November 14)
San Diego — Route 29 (December 12)

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 XXXIII’s TOP TEN – PART TWO: MORE OF 2019’s MOST SIGNIFICANT STRUCTURING TECHNIQUES AND AVOIDANCE OF FOOT FAULTS

HOT PARTNERSHIP AND LLC TOPICS FOR 2019

  • Planning opportunities using Qualified Opportunity Zones
  • Coordinating §704(b), §704(c) and §752 in acquisitive transactions
  • Analysis of the impact of the carried interest rules under the expected proposed regulations, including:
    • Measuring the applicable holding period of partnership interests and underlying assets
    • How, if at all, the rules apply to §1231 and §197 assets
  • Application of the anticipated guidance concerning the excess business loss and net operating loss rules
  • A potpourri of recent partnership and LLC developments

HOT S CORPORATION TOPICS FOR 2019

  • §199A planning opportunities in an S corporation setting
  • Integrating the §461(l) excess business loss rules and ESBTs
  • Is the “economic outlay” doctrine still alive for back-to-back loans
  • A potpourri of recent S corporation developments

 


The faculty members will utilize extensive case studies and examples to illustrate the issues to be discussed. Questions are taken from the audience at any time, as well as posed to the audience hourly throughout the program. 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.