This CLE/CPE course will provide tax counsel with a comprehensive guide to the tax consequences of contributing appreciated property to a partnership or multi-member LLC. The panel will discuss the specific tax treatment of appreciated property's contribution with debt, depreciation allocation, both... Read More

The CLE/CPE course will review the tax issues involved with structuring purchase agreements for partnership or LLC interests. The panel will address allocation of income gains and losses, allocation of the purchase price, payment terms in the purchase agreement, and the impact of current tax law and... Read More

This CLE/CPE course will provide tax counsel and advisers with a detailed analysis of the tax implications of equity compensation grants in partnerships and LLCs. The panel will discuss profit versus capital interests, phantom equity, the application of Section 83, carried interest, and best tax pla... Read More

This CLE/CPE course will provide tax counsel with a comprehensive guide to provisions allocating tax credits within a partnership agreement. The panel will discuss what criteria to evaluate in determining whether any tax credit allocation will be respected and go into detail on provisions for alloca... Read More

This CLE/CPE course will provide tax counsel with comprehensive guidance on navigating the rules governing mandatory Section 732(d) basis adjustments on distributed property by partnerships where there is no Section 754 election in place. The panel will discuss the application challenges surrounding... Read More

This CLE/CPE course will provide tax advisers with knowledge and tools to advise partnership clients converting to a tenancy-in-common form of real estate ownership. Tax advisers may recommend such a conversion in contemplating a future sale of property or creating a master limited liability company... Read More

This CLE/CPE course will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions. Read More

This CLE/CPE course will provide tax counsel and advisers with the guidance necessary to implement targeted partnership tax allocations correctly. The panel will explain the complex requirements of IRC 704(b) and provide best practices for maximizing the tax benefits of targeting partnership allocat... Read More

This CLE/CPE course will address recent final IRS regulations on interest deduction limitations under Section 163(j). The panel will discuss the impact of the regulations on partnerships and CFCs, rules for computing ATI and determining the deduction cap, special carryover and transition rules, and... Read More

This CLE/CPE course will provide tax counsel, accountants, and other advisers with an in-depth understanding of Section 199A and the mechanics of calculating and claiming the qualified business income deduction. The panel will discuss the strict rules, requirements, and limitations of IRC Section 19... Read More

This CLE/CPE course will provide tax counsel and advisers with specific and practical guidance to navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss common pitfalls and uncertainties under current tax law and outline best practices to struct... Read More

This CLE/CPE course will guide tax counsel and advisers on the current tax law's impact on the treatment of carried interest and available planning opportunities. In addition, the panel will discuss recent IRS final regulations, the application of Sec. 1061, Sec. 1231 property, implications of relat... Read More

This CLE/CPE course will guide tax counsel and advisers on the IRS final regulations, the tax treatment of carried interest, and available planning opportunities. The panel will discuss the application of Sec. 1061, modifications to the capital interest exception, applicable partnership interests (A... Read More

This CLE/CPE course will guide tax counsel and advisers on key tax rules for net operating losses (NOLs) and their impact on tax planning for taxpayers. The panel will discuss changes to the NOL carryback and carry-forward rules and limitations under current tax law, its effect on leveraging reduced... Read More

This CLE/CPE course will provide tax professionals and advisers guidance on Bipartisan Budget Act (BBA) audit procedures and rules and recent IRS enforcement actions and guidance. The panel will describe the partnership audit processes in detail, outlining the changes that facilitate IRS audits of p... Read More

This CLE/CPE course will provide tax counsel and other tax professionals an in-depth analysis of critical tax challenges for partnerships with foreign partners. The panel will discuss tax considerations when making partnership distributions to foreign partners, withholding and reporting requirements... Read More

This course will provide a focused and practical guide to tax counsel in drafting partnership tax distribution provisions. The panel will define the issue of "phantom income" and detail the negotiating process and strategies on whether to include tax distributions. The panel will also provide sample... Read More

This CLE/CPE course will guide tax professionals on the essential tax issues for umbrella partnership structures. The panel will discuss tax considerations for Up-C and UPREIT structures, the application of Sec. 162(m) to compensation paid by partnerships, key issues stemming from tax receivable and... Read More

This CLE/CPE course will guide tax professionals on critical tax challenges and recent developments for S corporations. The panel will discuss key tax law regulations and developments impacting S corporations, IRS guidance, the impact of the CARES Act and related PPP loan forgiveness, QBI deduction,... Read More

This CLE/CPE course will provide tax counsel with an up-to-date look at the drafting, commercial, and compliance implications of the partnership audit rules, including a discussion of IRS guidance on issues presented by the statute. The panel will describe the partnership audit processes in detail,... Read More

This CLE/CPE course will provide tax counsel a critical analysis of the impact of Section 199A qualified business income (QBI) deduction on the tax treatment of guaranteed payments to partners. The panel will discuss the default treatment of payments for services to a partner under Section 707 and t... Read More

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. T... Read More

This CLE/CPE course will provide tax counsel and advisers guidance on tax and related issues for businesses engaged in the cannabis industry. The panel will discuss critical federal and select state tax rules impacting cannabis businesses, recent tax court decisions, Section 280E, forfeiture, and ba... Read More

This CLE/CPE course will guide tax counsel and advisers to resolve complex tax questions confronting pass-through entities with a presence in more than one state. Our panel will brief attendees on state recognition rules and other complexities that apply to multistate S corps, LLCs, and partnerships... Read More

This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and partnership interests or property distributions; review the impact of the Section 754 election for in... Read More

This CLE/CPE course will guide tax professionals on the tax issues stemming from partnership non-cash property distributions. The panel will discuss critical issues in structuring non-cash property distributions, key exceptions, questions in applying Sections 751, 704(c), 707, 731(c), 737, and 752,... Read More

This CLE/CPE course will guide tax professionals and advisers on grasping critical tax collection and audit-related issues and solutions in light of the COVID-19 pandemic. The panel will discuss essential items of the new IRS People First Initiative and subsequent guidance including, unique complian... Read More

This CLE/CPE course will provide tax counsel and advisers with a specific and practical guide to navigating the tax rules that apply to the redemption of S corporation interests. The panel will discuss characterization as a sale or exchange versus distribution, tax consequences associated with such... Read More

This CLE/CPE course will guide corporate and tax counsel on the various methods of structuring waterfall distribution provisions in LLC and partnership agreements. The panel will examine a variety of economic and tax considerations such as timing and types of distributions (including tax distributio... Read More

This CLE/CPE course will guide tax counsel on the available tax planning strategies in structuring tiered partnerships. The panel will discuss tax considerations for structuring tiered partnerships, treatment of allocations and deductions, the impact of tax reform and new IRS partnership audit rules... Read More

This CLE/CPE course will provide tax counsel and advisers with specific and practical guidance to navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss common pitfalls and uncertainties under current tax law and outline best practices to struct... Read More

This CLE/CPE course will provide tax counsel and advisers guidance to IRS rules on the designation of partnership representatives for purposes of the centralized audit rules. The panel will discuss the regulations under Section 6223 and the impact on pass-through entities, IRS procedural and adminis... Read More

This CLE/CPE course will guide tax professionals on critical issues in the implementation of Section 199A qualified business income (QBI) deductions and essential items of focus for an IRS examination and audit. The panel will discuss what to expect when the IRS begins auditing tax returns claiming... Read More

This CLE/CPE course will provide tax professionals an in-depth analysis of qualified opportunity funds (QOFs), specifically focusing on recent IRS regulations and partnership disguised sales. The panel will discuss current IRS regulations on the application of disguised sale rules to investments in... Read More

This CLE/CPE course will provide tax counsel, advisers, and compliance professionals with a practical guide to navigating the state tax complexities involved in multi-tiered partnerships. The panel will discuss various state rules governing apportionment of income from lower-tier pass-through entiti... Read More

This CLE/CPE course will provide guidance to tax counsel and advisers on BBA audit regime issues faced by buyers and sellers of partnership interests. The panel will discuss key points of interest in negotiating and structuring purchases or sales of partnership interests in light of the new partners... Read More

This CLE/CPE course will provide tax counsel and advisers with an in-depth analysis of the loss limitation rules of Section 461(l) for non-corporate taxpayers passed in the 2017 tax reform bill. The panelist will discuss what items are included or excluded in the business loss calculations, the effe... Read More

This CLE/CPE course will provide guidance to tax counsel and advisers on the new tax law's impact on the treatment of carried interest and available planning opportunities. The panel will discuss the application of Sec. 1061, Sec. 1231 property, implications of related party transactions, and planni... Read More

This CLE/CPE course will guide corporate and tax counsel on the various methods of structuring waterfall distribution provisions in LLC and partnership agreements. The panel will examine a variety of economic and tax considerations such as approaches to drafting priority returns (internal rate of re... Read More

This CLE/CPE course will provide tax counsel and advisers with a review of the application and impact of the current tax law on pass-through entities. The panel will discuss new tax law changes impacting pass-through entities, recent IRS regulations, and provide tax planning strategies to optimize t... Read More

This CLE/CPE course will provide tax counsel and advisers with a specific and practical guide to navigating the tax rules that apply to the redemption of S corporation interests. The panel will discuss characterization as a sale or exchange versus distribution, tax consequences associated with such... Read More

This CLE/CPE course will provide tax professionals with an up-to-date look at the impact of the new IRS partnership audit rules on state tax regulations, audits, assessments and collection procedures. The panel will discuss recently released IRS final regulations, an overview of the new partnership... Read More

This CLE/CPE course will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions. Read More

This CLE/CPE course will provide tax counsel and advisers with a review of the application and impact of the new tax bill on pass-through entities. The panel will discuss new tax law changes impacting pass-through entities and provide tax planning strategies to optimize tax benefits and avoid pitfal... Read More

This CLE/CPE course will guide tax professionals and advisers on structuring contribution-default remedies for LLCs and partnerships. The panel will discuss the complexities of contribution-default remedies, such as interest dilution, set-offs and loans. The panel will also tackle a variety of tax i... Read More

This CLE/CPE course will guide tax counsel and advisers on navigating the complexities of characterizing partnership liabilities as recourse or nonrecourse. The panel will explain the significant tax and economic consequences for partners caused by distinctive treatments under the current tax code a... Read More

This CLE/CPE course will provide counsel and tax professionals an instructive review of recent trends in using series LLCs. The panel will compare the advantages and disadvantages, discuss federal tax implications of tax reform, analyze existing IRS guidance and examine tax pitfalls and alternatives... Read More

This course will provide tax counsel and advisers with techniques to overcome challenges associated with inadequate basis in S corporations. The panel will discuss IRS regulations that provide resolution to some of the most confusing areas of inadequate basis. Read More

This CLE/CPE course will provide tax counsel and partnership advisers with a practical, comprehensive guide to the "fractions rule," governing allocations between tax-exempt partners and taxable partners. The panel will define the specific issues and challenges that the fractions rule presents in st... Read More

This CLE/CPE course will provide tax counsel and advisers with a comprehensive and practical guide to navigating the complex requirements of IRC Section 704(c) in structuring partnership agreements. The panel will offer practical drafting tools, including sample language, for ensuring that partnersh... Read More

This CLE/CPE course will provide tax counsel and advisers with a practical guide to structuring partnership transactions to qualify for partnership merger treatment as a continuing interest under Section 708. The panel will identify tax issues of collapsing separate upper-tier partnerships (UTPs) an... Read More

This CLE/CPE course will provide tax counsel and advisers with a thorough, practical guide to the disguised sale rules for partnerships since the Fourth Circuit's decision in Route 231 LLC v. Commissioner. The panel will discuss the facts and circumstances tests listed in the Treasury Regulations, d... Read More

This CLE/CPE course will provide tax counsel with an exploration into the ramifications of IRS Notice 2015-54, released Aug. 6, 2015, which will generally make a taxable event of any contribution of appreciated property by a U.S. person to a related partnership, unless strict requirements are satisf... Read More

This course will provide a focused and practical guide to tax counsel in drafting partnership tax distribution provisions. The panel will define the issue of "phantom income," and detail the negotiating process and strategies on whether to include tax distributions. The panel will also provide sampl... Read More

This CLE/CPE course will provide tax counsel and family office advisers with the understanding and tools to implement best practices in drafting trust documents in anticipation of trust ownership of closely-held businesses, as well as integrating the operating documents of those businesses to preser... Read More

This CLE course will provide tax counsel with techniques to determine allocation of recourse and nonrecourse liabilities in light of new, coming IRS regulations. The panel will review the impact of the revisions for structuring partnership transactions and agreements, including new net value, bottom... Read More

This CLE course will provide tax counsel with a road map to navigate long-awaited final regulations intended to clarify the Net Investment Income (NII) tax. The experienced panelists will discuss planning opportunities to leverage new rules for regrouping, real estate safe harbor and the new propose... Read More

This CLE course will provide tax counsel with clarification of gain/loss recognition rules of IRC Sect. 704(c)(1)(B) and Sect. 737 for partnerships. Our panel will discuss the general rules of applicability and exceptions, review characterization rules, and offer best practices for dealing with othe... Read More

This CLE course will discuss unique allocation issues for tiered partnerships under 704(b) and (c), address application of the allocation rules to mergers and dispositions of 704(c) property, as well as basis adjustments. Read More

This teleconference will provide tax practitioners with an in-depth review of the rules for partnership basis adjustments and distributions under Code sections 731 through 737, 751(b) and 755. The panel will also outline how to avoid taxable pitfalls in applying the rules to partnership transactions... Read More

This teleconference will discuss the application of these new taxes, the definition and calculation of the tax on net investment income, tax planning strategies for owners and members of pass-through entities, and avoidance of unique tax traps. Read More

This teleconference will provide guidance for tax counsel on tax allocation provisions for partnerships and LLCs taxed as partnerships. The panel will outline steps to meet the tax goals for both the partners and the entity. Read More

This teleconference will analyze the basis adjustment rules associated with sales, transfers and partnership interests or property distributions; review the impact of the Section 754 election for individual partners and the partnership; and discuss structuring transactions to avoid unintended tax co... Read More

This teleconference will provide tax advisors with an overview of frequently misunderstood and often overlooked tax considerations affecting S Corporations. The panel will explain the key differences between S-Corps vs. LLCs and partnerships. Read More

This teleconference will provide tax counsel with a guide to the impact of IRC Section 707 on business transactions between partnerships and partners. The panel will explore the analyses used by the IRS and courts to deem business deals as disguised sales and abusive situations triggering taxable ev... Read More

This CLE course 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. Read More