IRC 1367 S Corporation Stock and Debt Basis Adjustments: New IRS Practice Unit Guidance
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to making stock and debt basis adjustments for S corporations in light of recent IRS Practice Unit guidance. The panel will discuss the specific transactions and events identified by the Service in the IPU as potential issues and offer practical suggestions to allocations and basis adjustments.
Outline
- Mechanics of calculating stock basis
- Section 1367 and regulatory guidance
- Common errors in adjustments that increase or decrease stock basis
- Basis adjustments for income or losses not claimed on tax return
- Basis treatment of life insurance premiums
- Tax credits
- Certain tax credit bonds
- Debt basis rules and structuring
- Debt basis rules and calculations
- Debt transactions subject to IRS challenge and disallowance
- Reducing existing debt basis
- Substantiating debt basis
Benefits
The panel will discuss these and other important topics:
- Debt basis adjustments that may be subject to IRS challenge and disallowance
- Proper basis adjustments for “distortions” created by items such as certain tax credit bonds
- Basis adjustments required for key-man life insurance premiums and proceeds
- Basis treatment for excess depletion expenses
Faculty
Brian T. Lovett, CPA, JD
Partner
Withum Smith+Brown
Mr. Lovett has extensive experience serving the tax needs of both public companies and closely-held businesses,... | Read More
Mr. Lovett has extensive experience serving the tax needs of both public companies and closely-held businesses, including all aspects of tax compliance for partnerships and corporations. He advises clients with regard to the structure and tax consequences of new business ventures, and assists with restructuring existing businesses for increased tax efficiency. Prior to joining his firm, he was with a “Big 4” accounting firm, working closely with large, multinational real estate investment companies.
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Lindsey Serrate, CPA
Managing Director
True Partners Consulting
Ms. Serrate has more than 20 years’ experience in private and public sector tax, including nine years at UBS... | Read More
Ms. Serrate has more than 20 years’ experience in private and public sector tax, including nine years at UBS Asset Management as the Head of Asset Management Tax – Americas, internal tax consultant for the onshore and offshore traditional, alternative, private equity and infrastructure businesses. She leads the firm's Chicago Flow-Through (Partnerships) practice and assists private equity firms, portfolio companies and hedge funds navigate the ever changing tax landscape and tax risk management challenges both nationally and globally. Previously, she worked for UBS Group Tax, Deloitte Tax LLP (financial services group) and Arthur Andersen (middle market tax practice) in Chicago.
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Professor Robert W. Jamison, CPA
Professor Emeritus of Accounting
Indiana University
Mr. Jamison is Professor Emeritus of Accounting at Indiana University, Purdue University, Indianapolis (IUPUI). His... | Read More
Mr. Jamison is Professor Emeritus of Accounting at Indiana University, Purdue University, Indianapolis (IUPUI). His principal area of specialization is S Corporations. He is the sole author of S Corporation Taxation, and co-author of Multistate Tax Guide to Pass-Through Entities, both of which are published annually by CCH, a Wolters Kluwer business. He is a regular contributor to Land Grant University Tax Education Foundation, Inc. National Income Tax Workbook and has contributed to Federal Tax Workshop. He presents advanced and update S Corporation seminars for various states' CPA societies and to other professional organizations. He is a member of the AICPA S Corporation Technical Resource Panel. He consults on S corporation and other business entity problems and has secured letter rulings from the IRS.
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