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


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

Structuring Techniques for 2022 and Beyond – An In-Depth Look at Closely Held Business Planning

  • Analyzing any new or proposed tax legislation and its impact on flow-through planning
  • Selected issues of concern when converting an LLC or an S corporation to a C corporation
  • A comprehensive look at various partnership and S corporation K-1 disclosure requirements
  • 2022's integration of estate planning with flow-through entities
  • CCA 202152018 – an IRS tightening of what is a qualified §1202 business or an aberration?
  • Dealing with the 2022 §163(j) change from EBITDA to EBIT
  • Lingering PPP reporting issues for the flow-through entity
  • The black hole of "unified basis" for partnership interests under Rev. Rul. 84-53: how deep is it and what to do?

Forum XXXVI's Top Ten: 2022's Most Significant Flow-Through Issues and Avoidance of Foot-Faults

Emerging Partnership and LLC Topics For 2022 and Beyond

  • 2022’s §704(b)/§704(c)/§752 structuring issues and techniques
  • Working with the "somewhat" alive debt-financed distribution exception to the disguised sale rules
  • Shifting basis on a partnership property distribution
  • The scope of the SE tax exception for rental real estate and other SE tax minimization techniques
  • The evolving thought process on the scope of tax distributions
  • Changing partnership residual ownership percentages and the capital shift issue

Hot S Corporation Topics For 2022 and Beyond

  • Why to convert from C to S status prior to an asset sale
  • Using ESBTs in combination with §678 "beneficiary" grantor trusts
  • S corporation stock and debt basis traps in following the new Form 7203 and its filing instructions
  • S corporation §338(h)(10) deemed asset sale transactions and tax gross-up payments

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

Program materials and presentations will provide information relating to the covered subject matter. None of the presenters, authors or publisher will be rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional adviser be engaged.

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