Form 6198 At-Risk Limitations: IRC 465 Calculations, Grouping, Elections and Schedules

Identifying Loss Deferrals, Recapture Requirements; Tracking Carry-Forward Amounts

A live 110-minute CPE webinar with interactive Q&A

Tuesday, September 26, 2017 (in 4 days)
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

This webinar will provide tax advisers with an advanced guide to reporting loss limitations on Form 6198. The panel will have an in-depth discussion into the Section 465 rules and offer comprehensive and practical guidance on the complexities of maintaining at-risk amount schedules and carry-forwards. The webinar will also detail tactics for freeing up carry-forward losses and dealing with loss recapture.


The at-risk loss limitation rules of IRC 465 have long challenged taxpayers and tax advisers alike. Section 465 serves as a barrier to prevent taxpayers holding partnership or S corporation shares from deducting current tax losses for activities in which they do not have an economic loss. For advisers and compliance professionals, determining which losses can be currently deducted and which must be deferred is complex.

Section 465(a) limits the current tax losses an individual may deduct from certain activities to the amount at which the taxpayer is “at risk” for that activity. The Section further defines amounts at risk as the amount the taxpayer contributed to the activity in cash and the adjusted basis of any other property, along with any recourse debt incurred directly for use in the activity. At-risk limitation calculations are reported on Form 6198.

Section 465 is one of three provisions taxpayers must contend with to claim losses from partnership or S corp ownership. Tax professionals must have a thorough and practical grounding of the at-risk rules, including activity grouping rules and how Section 465 works with basis limitations and Section 469 passive activity loss rules to avoid costly tax mistakes.

Listen as our experienced panel of practitioners offers a thorough and practical guide to the planning, calculation and reporting requirements of the Section 465 at-risk limitation rules.


  1. Taxpayers and activities subject to Section 465 at-risk limitations
  2. Activities that must be reported separately
  3. Aggregation rules
  4. Determination of amounts at risk
  5. Nonrecourse debt and amounts deemed not at risk
  6. Recapture rules
  7. Form 6198


The panel will discuss these and other important topics:

  • What does—and does not—qualify as “at risk” for purposes of calculating loss limitation on pass-through activities?
  • What elections and grouping approaches are available to minimize the impact of loss deferral due to at-risk limitations?
  • Reporting carry-forwards and recapture of prior loss deductions on Form 6198
  • Maintaining schedules and substantiation of carry-forward disallowed losses

Learning Objectives

After completing this course, you will be able to:

  • Establish what constitutes at-risk amounts for purposes of loss limitation calculations
  • Discern activities that may or must be grouped, and which activities must be separated, for amount at risk limitation purposes
  • Determine available elections to minimize loss limitations
  • Recognize scenarios where deferral, or recapture, of deductions based on at-risk loss limitations occur
  • Identify calculations and required schedules to complete Form 6198


Robert S. Barnett, Partner
Capell Barnett Matalon & Schoenfeld, Jericho, N.Y.

Mr. Barnett practice encompasses business and tax planning, estate planning and federal and state tax dispute resolution, among other engagements. He is a frequent writer on tax topics for professional journals.

Lewis Taub, Managing Director
CBIZ, New York

Mr. Taub has more than 25 years of experience advising closely-held middle-market companies in a wide variety of industries, with an emphasis on consumer products. He has significant experience with tax matters related to private, multistate and multinational pass through entities including S corporations and partnerships, as well as high-net-worth individuals. He also has significant expertise in tax planning for private equity groups that invest in businesses.

Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $147.00

Live Webinar & CPE Processing $182.00

CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. The webinar assumes specific knowledge and understanding of the Section 469 Passive Activity Rules, the material participation rules, recognizing complex K-1 schedules; familiarity with the grouping disclosure rules,

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recorded Event

Includes full event recording plus handouts (available after live webinar).

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Available ten business days after the live event

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Live Webinar & Audio Download $194.00

Recorded Audio Download (MP3) Only $47.00 with Registration/MP3 Combo

Live Webinar & DVD $194.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $47.00 with Registration/DVD Combo


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