Structuring Tax Provisions in Partnership and LLC Operating Agreements
Effective Allocations With Flow-Through Entities
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE webinar will update tax counsel on the key issues to address in operating agreements for partnerships and LLCs taxed as partnerships. The panel will offer best practices for crafting agreements that reflect effective tax compliance and planning going forward.
Outline
- Key tax issues/provisions
- Capital contributions
- Distributions
- Profits and losses
- Capital accounts
- Tax audit provisions
- Transactions between partners and partnerships
- Liquidations
- Tax consequences of those provisions
- Capital contributions
- Distributions
- Allocation provisions
- Capital accounts
- Tax audit provisions
- Transactions between partners and partnerships
- Liquidations
- Tax planning strategies for drafting partnership/LLC agreements
Benefits
The panel will analyze these and other critical partnership priorities:
- Tax matters to address in partnership operating agreements, including allocating tax items on contributed property, distributing tax for partners' liabilities on shares of income, and alerting members to liquidation issues.
- Specialized issues to consider, such as disproportionate allocations of income or loss items and giving partners an interest in exchange for future or past services.
- Integration of effective tax planning for the entity and its members during the creation of the operating agreement.
Faculty
Andrew W. Ratts
Partner
Winston & Strawn
He advises clients on tax issues relating to business formations, acquisitions, divestitures, debt reorganizations and... | Read More
He advises clients on tax issues relating to business formations, acquisitions, divestitures, debt reorganizations and executive compensation. He has particular experience with the federal income taxation of pass-through entities, such as partnerships, limited liability companies, S corporations and grantor trusts, and of financial instruments and derivatives.
CloseDavid L. Forst
Partner
Fenwick & West
He focuses on international corporate and partnership taxation and is the practice group leader of the firm's tax... | Read More
He focuses on international corporate and partnership taxation and is the practice group leader of the firm's tax group. He also lectures at Stanford Law School and is an editor of and regular contributor to the Journal of Taxation and an editor of the Journal of Passthrough Entities.
CloseCarolyn R. Turnbull
Director of Tax
Moore Stephens Tiller
She has extensive experience dealing with complex partnership and corporate tax issues, including special allocations,... | Read More
She has extensive experience dealing with complex partnership and corporate tax issues, including special allocations, maintenance of capital accounts, basis and at-risk computations, consolidated returns, multi-state apportionment and allocation computations, state income and composite tax returns, state and federal tax credits, international tax issues, and mergers and acquisitions.
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