Section 163(j) and the CARES Act: Special Partnership Rules, International Tax and U.S. State Tax Implications
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax professionals a critical analysis of the recent changes made to Section 163(j) under the CARES Act. The panel will discuss new special partnership rules and the impact of the revisions to Section 163(j) under the CARES Act on international and U.S. state taxes. The panel will also offer effective tax planning techniques for pass-through entities in light of the CARES Act and provisions of Section 163(j).
Outline
- Section 163(j) overview, CARES Act changes to Section 163(j)
- Special partnership rules
- International tax impact
- State tax impact
Benefits
The panel will review these and other key issues:
- The impact of the CARES Act on Section 163(j)
- Critical provisions of Rev. Proc. 2020-22
- Increase of ATI limitation for partnerships
- Using pre-CARES Act Section 163(j) rules in the context of the BEAT
- Potential compliance issues based on state conformity
- Specific exceptions to the application of new Section 163(j)
- How to calculate ATI for purposes of determining deduction limitations
Faculty
Andrew L. Howlett
Member
Miller & Chevalier
Mr. Howlett practices in the area of federal income tax with an emphasis on tax planning, tax-related... | Read More
Mr. Howlett practices in the area of federal income tax with an emphasis on tax planning, tax-related transactional matters and tax controversy. He provides counsel on domestic and cross-border corporate tax issues, including advice on asset and stock purchases, joint ventures, mergers, recapitalizations and spin-offs. He also advises individuals, and has substantial experience with the IRS’s voluntary disclosure program. He has a substantial pro bono practice, including assisting 501(c)(3) organizations and individuals with a broad range of tax issues.
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Charles Kaufman
Managing Director
KPMG
Mr. Kaufman’s practice includes advising clients regarding transactions involving the taxation of partnerships,... | Read More
Mr. Kaufman’s practice includes advising clients regarding transactions involving the taxation of partnerships, real estate investment trusts, and other pass-through entities. He advises private equity funds and tax-exempt entities in their investment activities and has experience advising both the sponsors of and investors in all types of private investment vehicles. Mr. Kaufman has advised clients with respect to numerous real estate transactions, corporate joint ventures, project finance transactions, securitization transactions, partnership restructurings and workouts, and cross-border financings and investments. In addition, he advises financial institutions in structuring and implementing structured financing and derivatives transactions.
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Bradley R. Wilhelmson
Managing Director
KPMG
Mr. Wilhelmson practices in the firm’s State and Local Tax (SALT) practice and serves as a dedicated resource for... | Read More
Mr. Wilhelmson practices in the firm’s State and Local Tax (SALT) practice and serves as a dedicated resource for the firm’s asset management and real estate clients assisting them on structuring, tax planning and compliance. Mr. Wilhelmson is KPMG’s primary tax technical resource for Illinois and Wisconsin taxes and advises clients on income, transactional, and franchise taxes. He also specializes in investor related state tax issues, including individuals and trusts. Mr. Wilhelmson works extensively on state nonresident withholding tax issues for large multiple-tier structures, and on SALT partnership tax issues, tax controversies and provisions for pass-through entities. He has authored articles and has been quoted in various tax publications, and additionally is a regular presenter on SALT issues at conference and training events.
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