Pass-Through Entities and COD Income: Sheltering Solvent Entity Owners From Insolvent Entity Taxable COD Income
Recording of a 110-minute CPE/CLE webinar with Q&A
This CLE/CPE webinar will provide tax advisors and counsel with a review of insolvent pass-through entities and the options available to protect solvent owners from realizing taxable cancellation of debt (COD) income. The program will highlight how COD income is treated for various types of business entities under the IRC and discuss IRC §108 exclusions as well as focus on recent developments that provide a strategy for protecting solvent owners of insolvent pass-through entities.
- IRC treatment of COD income for various types of entities
- Entity owner(s) “property right” to terminate and elect a new tax classification
- Strategies for pass-through entities to lock in COD income at the entity level
Our panel will review these and other key issues:
- What is the impact of the dual authority for insolvent pass-through entity owners to terminate and elect entity tax classification?
- What is the precise timing required for terminating and electing tax classification in order to protect solvent owners?
- What guidance can tax advisors offer to overcome creditor challenges to an insolvent pass-through changing its tax status to avoid COD income being attributed to its owners?
Robert A.N. Cudd
Mr. Cudd advises both domestic and foreign entities on tax-efficient structures as well as on transactions between the... | Read More
Mr. Cudd advises both domestic and foreign entities on tax-efficient structures as well as on transactions between the domestic and foreign entities. He has extensive experience in public and private REITs, timber and infrastructure funds, solar and wind projects, energy and pipelines, reorganization of domestic and foreign corporations and partnerships, private equity funds, controlled foreign corporations and PFICs, and bankruptcy and insolvency.Close
Jeffrey R. Davine
Mr. Davine's practice focuses on federal and local taxation, tax planning, and estate planning issues,... | Read More
Mr. Davine's practice focuses on federal and local taxation, tax planning, and estate planning issues, including pass-through entities, business transactions, real estate taxation, certain employee benefits, tax controversies, and trusts, estates, and probate. He represents and advises a broad range of buyers and sellers of businesses together with tax advice, planning, and structuring, and his practice also involves foreign tax matters.Close
Joseph K. Fletcher, III
Glaser Weil Fink Howard Avchen & Shapiro
Mr. Fletcher has particular expertise ranging from the taxation of mergers and acquisitions to international taxation... | Read More
Mr. Fletcher has particular expertise ranging from the taxation of mergers and acquisitions to international taxation to the resolution of tax controversies. He has counseled Fortune 500 companies as well as start-ups and middle-market businesses on all aspects of corporate and partnership taxation, including acquisitions and divestitures, joint ventures, and tax controversies.Close
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CPE On-DemandSee NASBA details.