Thirty-Eighth Annual Partnership, LLC & S Corporation Tax Planning Forum^®

Program

This program is presented in a transactional format, with the faculty members utilizing 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. (Some of the program may not be covered orally.)

I Structuring Techniques for 2024 and Beyond – An In-Depth Look at Closely Held Business Planning

II Forum XXXVIII’s Top Ten: 2024’s Most Significant Flow-Through Issues and Avoidance of Foot Faults

III Emerging Partnership and LLC Topics For 2024 and Beyond

• Soroban, Sirius, Denham Capital and Point72 updates and other §1402(a)(13) SE tax developments
• The newly proposed anti-basis-shifting regulations and their impact on everyday transactions
• How the newly proposed related-party regulations impact partnership/partner transactions
• 2024’s §704(b)/§704(c)/§752 structuring issues and techniques
• TIC interests vs. Delaware Statutory Trusts as §1031 exchange vehicles
• Preferred returns as taxable capital shifts?
• The anticipated Seventh Circuit decision in Tribune Media and the breadth of a non-taxable debt-financed distribution
• Code §199A planning to limit the impact of the taxable income threshold
• Structuring the acquisition of an estate’s partnership interest in a tax-efficient manner
• CCA 202352018 – the IRS reverses course on grantor trust reimbursement clauses
• When to opt into the proposed §751 regulations

IV Hot S Corporation Topics for 2024 and Beyond

• The Supreme Court decision in Connelly – the need to avoid corporate-owned life insurance and how to structure an insurance partnership to implement a stock purchase agreement
• Avoiding current gain recognition by the non-selling shareholder on an S corporation asset sale
• Using an F Reorganization in a tax-efficient manner
• Exploring QSST uncertainties
• Avoiding traps under the §453A interest toll charge rules
• CCA 202335014 and an ESBT’s use of an NOL
• Integrating trust ownership of S corporation stock with the 65-day post-year-end distribution rule

V Dealing With Uncertain §1202 Stock and §1045 Rollover Issues

Chuck, Michael and Scott will entertain questions from attendees throughout the virtual programs (which include scheduled live Q&A sessions) and during and after the in-person programs.