3.8% Federal Net Investment Income Tax Challenges for Tax Professionals
Tackling Tax Compliance and Planning for High-Income Individuals and Pass-Through Entities
Recording of a 110-minute CPE/CLE webinar with Q&A
This webinar will address practical planning and compliance issues that taxpayers should anticipate arising from the 3.8% net investment income (NII) tax, given the likelihood for their drawing extra IRS attention.
Outline
- Mechanics and thresholds of the 3.8% NII tax
- Special issues for individual, estate and trust taxpayers
- Potential issues for business taxpayers and investors in businesses
- Passive vs. active activities
- Impact on sales or transfers of interests in closely held entities
Benefits
The panel will explore relevant and practical topics such as:
- Surprises in the working capital exception for owners of non-passive businesses using investment or interest-bearing accounts.
- How to regroup activities and potentially meet the material participation standards for non-passive activity.
- Rental activities such as "triple net leases" that seem most likely to draw an IRS challenge.
- Steps for a deemed sale analysis before selling a partnership or S corporation interest.
Faculty
Jon P. Brose
Partner
Seward & Kissel
Mr. Brose represents investment funds and their managers on all aspects of their businesses, including management... | Read More
Mr. Brose represents investment funds and their managers on all aspects of their businesses, including management entity and fund formation, seeding arrangements, M&A, partnership tax and international tax issues, compensation arrangements, and ongoing investment activities and transactions. He also provides tax advice regarding securities offerings, structured products, and a variety of other commercial transactions and capital markets activities.
CloseMitchell S. Fuerst
Managing Partner
Fuerst Ittleman David & Joseph, PL
Mr. Fuerst concentrates his practice in the areas of tax law and tax litigation, among others. His ability to... | Read More
Mr. Fuerst concentrates his practice in the areas of tax law and tax litigation, among others. His ability to thoroughly analyze the strategies and goals of corporations, coupled with nearly 30 years of diverse legal experience, places him in a unique position to effectively guide businesses through the complexities of governmental regulations and corporate compliance requirements, while consistently maximizing shareholder value. Mr. Fuerst is a former trial attorney with IRS’ Office of Chief Counsel.
ClosePatti S. Spencer
Atty
Spencer Law Firm
Ms. Spencer assists clients with federal estate, gift and generation-skipping tax planning, estate and trust... | Read More
Ms. Spencer assists clients with federal estate, gift and generation-skipping tax planning, estate and trust administration, business succession planning, tax planning for qualified plan distributions, fiduciary income tax, and corporate tax planning. She taught Estate and Gift Taxation, Trusts and Estates, and Estate Planning at Boston University School of Law for 8 years, and recently taught Federal Income Taxation at Franklin and Marshall College. She is the author of two books on estate matters and a weekly newspaper tax column.
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