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

Program

The 2025 program will be finalized in spring 2025 and will be updated as warranted by new developments; however, the program is expected to include:

I Structuring Techniques for 2025 and Beyond – An In-Depth Look at Closely Held Business Planning

II Forum XXXIX’s Top Ten: 2025’s Most Significant Flow-Through Issues and Avoidance of Foot Faults

III Emerging Partnership and LLC Topics for 2025 and Beyond

• Where we stand with the extension of TCJA provisions and other legislative action impacting closely held businesses
• Developments in the §1402(a)(13) limited partner SE tax exclusion arena
• 2025's §704(b)/§704(c)/§752 structuring issues and techniques
• Update on the application of Loper Bright (elimination of deference to Treasury regulations) to flow-through entities
• The impact of the final §752 regulations governing related-party debt allocations
• The status of the proposed Treasury/IRS guidance impacting basis-shifting transactions and a discussion of Otay (if decided)
• The §1202 tool box for using the 100% capital gain exclusion, including the integration of §1202 and corporate reorganizations
• The controversial IRS §1031 drop-and-swap analysis in PLR 202450005 and PLR 202449007
• The pressure points in using an installment note to avoid boot in a §1031 exchange

IV Hot S Corporation Topics for 2025 and Beyond

• Surk and the Tax Court's mysterious creation of "negative basis"
• Combining §338(h)(10), §453(h), §453B(h) and §199A
• Using the §1368(e)(3) election to avoid foot faults when distributing C e&p from an S corporation
• Potential pitfalls when rescinding a transaction

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.