Key Tax Provisions in LLC Operating Agreements: Interpreting Special Allocation, Safe Harbor, DRO, QIO Clauses
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This course will review LLC operating agreements from the perspective of a tax professional. Our partnership veteran will explain how to identify the common language in arrangements for safe harbor provisions, deficit restoration obligations (DROs), qualified income offsets (QIOs), loss limitation provisions, special allocations under Section 704©, as well as offer suggestions for handling provisions that may not match the partners' or IRS expectations.
- Operating agreements: an overview
- Special allocations
- Substantial economic effect
- Safe harbor agreements
- Noncompliant operating agreements
- Best practices
Our panelist will cover these and other critical issues:
- Identifying boilerplate language added for tax compliance to operating agreements
- Differences between S corporation and partnership allocations
- The types of safe harbor agreements
- Meeting Treasury's substantial economic effect requirements
- Handling language that does not match partners' expectations
- When a qualified income offset is required
Jeffrey Clayman, CPA, JD, LLM
Tax Senior Manager
Mr. Clayman has over 18 years of public accounting experience with a focus on for-profit businesses in many different... | Read More
Mr. Clayman has over 18 years of public accounting experience with a focus on for-profit businesses in many different industries. He has expertise in federal reporting and compliance for c-corporations, s-corporations, partnerships and limited liability companies. Mr. Clayman is highly experienced in analyzing all types of transactional documents, purchase and sale agreements, debt instruments, corporate documents and partnership agreements.Close
Brittany Perez-Trepichio, CPA, MBA
Mrs. Perez-Trepichio is a Tax Manager in the partnership tax group of Withum Smith+Brown. Her public accounting... | Read More
Mrs. Perez-Trepichio is a Tax Manager in the partnership tax group of Withum Smith+Brown. Her public accounting experience focuses on for-profit pass-through entities. Her expertise includes analyzing and implementing transactional tax matters including mergers and acquisitions, transfers and redemptions of partnership interests, and complete liquidations. She also has a passion for understanding and implementing key tax provisions in partnership operating agreements including income allocations, built-in-gain contributions, and step-up/(down) provisions related to 754 elections.Close
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