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Top 12 Issues for Partnerships, LLCs and S-Corps - NEW
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| Date |
October 06, 2010
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| Location | German American Society, Omaha, NE |
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| Course Time |
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8:30 a.m. to 4:30 p.m. |
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This course reviews specialized issues in the taxation of partnerships, LLCs and S-Corps. Twelve common issues, each providing significant tax-planning opportunities or potential traps for the unwary, are identified and the tax consequences associated with different types of pass-through entities are explored. Case studies are included with each issue to illustrate how seemingly routine transactions often trigger complex or unexpected tax provisions. Some studies also illustrate how entity choice affects the ultimate tax consequences associated with a particular transaction.
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| Course Highlights & Objectives |
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Application of self-employment tax rules to partnerships and LLCs, including application to Sec. 1402 retirement distributions to partners or LLC members. Assessing the character of pass-through items to non-participatory partners (including LLC members). Effective use of partnerships in planning Sec. 1031 exchanges. Estate tax planning using family limited partnerships. Planning for compensatory transfers of partnership interests, including issuance of partnership “options.” Potential application of Sec. 704(c) following partnership capital account “book-ups” and partnership mergers. Properly structuring distributions to retiring or expelled partners to maximize tax benefits to the partnership/LLC and the departing partner/member. Protecting LLC members’ at-risk amounts for tax purposes. Tax implications of different options for restructuring troubled debt. Using single-member LLCs in tax planning.
Participants will be able to Analyze pass-through entity balance sheets to recognize potential tax opportunities or costs; Consider and evaluate alternative approaches to common transactions that may take advantage of opportunities or minimize costs; More thoroughly evaluate the impact of entity choice on different types of transactions, ranging from the renegotiation of debt instruments to liquidating distributions to owners, to determining the owners’ liability for self-employment taxes; and Recognize how multiple provisions of the tax law are applied simultaneously to complex transactions. |
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| Who Should Attend |
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| Tax practitioners whose client base includes significant pass-through entity clients, or clients with interests in pass-through entities. |
| Course Level | Advanced |
| Prerequisites | Intermediate courses in taxation of partnerships & LLCs and taxation of S-Corps, or equivalent knowledge or experience. |
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| Discussion Leader | Peter Towle, AICPA |
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| Additional Information: |
Parking is available on site and lunch is provided. |
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| Fee |
$230 - Society Member
$260 - AICPA or Society Nonmember
$290 - AICPA & Society Nonmember |
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