Mastering S Corporation At-Risk Loss Limitations: Beyond Calculations to Proactive Planning
Grouping Strategies, Aggregation, Mergers and Q-Sub Elections
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide a deeper dive into the planning implications of S corporation at-risk loss limitations by giving tax advisers detailed strategies for avoiding negative tax outcomes by managing the limitations through often complex planning. The panel will discuss techniques such as grouping and qsub elections, as well as leverage contribution strategies to enable taxpayers to navigate around loss limitation rules to utilize current-year tax losses.
Outline
- At-risk limitation rules
- What provides S corp shareholder with at-risk basis
- Tracing at-risk amounts by activity
- Grouping strategies
- Qsub
- Illustrations
Benefits
The panel will discuss these and other critical topics:
- The at-risk loss limitation rules of IRC 465, and how they differ from at-risk amount provisions in other sections of the Code
- Basic overview of at-risk basis
- Grouping of activities to reallocate at-risk amounts
- Tracing rules
- Strategies to free-up suspended loss carryover amounts
- How to utilize mergers and QSSTs to avail a taxpayer of losses that would otherwise be subject to loss limitations
Faculty

Robert S. Barnett, CPA
Partner
Capell Barnett Matalon & Schoenfeld
Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and... | Read More
Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and partnership law and charitable planning. His experience includes surrogate’s court practice, tax dispute resolution in both federal and state jurisdictions, and tax court representation. Mr. Barnett frequently assists clients in structuring financial transactions and charitable gifts. His articles and lectures encompass a wide variety of topics, including business succession, estate planning, generation-skipping, stock options, effective strategies for removing tax liens, proper utilization of the marital deduction and utilization of partnership elections.
CloseDarren J. Mills
Managing Director
Alvarez & Marsal Taxand
Mr. Mills has more than 20 years of experience advising both middle market companies and large multi-nationals... | Read More
Mr. Mills has more than 20 years of experience advising both middle market companies and large multi-nationals regarding complex federal and international tax issues. He also advises both strategic and financial buyers in tax due diligence and structuring as well as providing sell-side due diligence/structuring. He has taught classes on S Corporations at Seton Hall University and the University of Baltimore School of Law.
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