Loss Limitations Analysis: Basis, At-Risk, Passive, and NOLs
Recording of a 110-minute CPE webinar with Q&A
This course will discuss the hierarchy of basis, at-risk, passive activity loss (PAL) limitations, net operating loss (NOL) limitations, and steps to avoid and mitigate the limitation of losses for owners of partnerships and S corporations.
Outline
- Basis
- At-risk limitations
- Passive loss limitations
- Net operating losses
- Section 461(l) excess business loss limitation
- Planning opportunities
Benefits
The panel will review these and other notable issues:
- The appropriate hierarchy for application of loss limitations
- What constitutes amounts at risk for partnerships and S corporations
- How can activities be aggregated to avoid PAL limitations?
- When losses are carried forward, and how are losses applied to different types of income?
Faculty

Matthew L. Roberts
Partner
Meadows, Collier, Reed, Cousins, Crouch & Ungerman
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar... | Read More
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, Income Tax and Business Planning, and Cryptocurrency and Digital Assets. He is Board Certified in Tax Law by the Texas Board of Legal Specialization. Mr. Roberts is a tax litigator and trusted advisor with extensive experience assisting both U.S. and international clients in successfully resolving various federal tax controversies, including civil and criminal liability cases. His expertise covers a broad spectrum of issues, such as tax audits, investigations, litigation, appeals, and collection matters.
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Joshua D. Smeltzer
Partner
Gray Reed
Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his... | Read More
Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his practice on defending taxpayers in all stages of civil and criminal tax proceedings, including sensitive audits and examinations. Mr. Smeltzer frequently represents corporations, complex partnerships, family offices, estates and trusts, and high-net worth individuals. His practice encompasses a variety of industries, with special expertise in real estate, energy, insurance, private equity, digital assets and blockchain technology. Mr. Smeltzer uses his background as a former U.S. Department of Justice lawyer to provide first-hand knowledge when the government is involved in litigation in designing an effective plan to litigate disputes, minimize risks and achieve as many client goals as possible. He has deep litigation and trial experience, both as a private and government lawyer, in controversies ranging from $500,000 to more than $1.5 billion.
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