You Are Invited To Annual Partnership, LLC & S Corporation Tax Planning Forum

This premier seminar, the “Annual Partnership, LLC & S Corporation Tax Planning Forum,” or simply the “Forum,” is an intensive flow-through entity tax planning seminar, which incorporates recent developments from Congress, Treasury, the IRS, case law and the many issues raised throughout the year by our attendees into the hottest flow-through planning techniques. Presented entirely new for the 37th year, the Forum provides attendees with cutting-edge strategies to take advantage of tax planning and business planning opportunities. As the Forum deals with advanced techniques, it is best suited for tax professionals who have a good working knowledge of flow-through taxation.
Read a summary of anticipated topics to be covered at the 2023 Tax Planning Forum.

This program is presented in a transactional format, so the faculty members will utilize practical examples to illustrate the issues to be discussed. An analysis of recent legislation and the latest cases, regulations and rulings will be integrated into each session. Program content and timing are based upon the current status of the law and may be modified if warranted by new developments. (Some of the program may not be covered orally.)

Structuring Techniques for 2023 and Beyond – An In-Depth Look at Closely Held Business Planning

-Analyzing any new tax legislation and its impact on flow-through planning
-Soroban and other §1402(a)(13) SE tax developments
-When is a QIO triggered and the impact of Clark Raymond
-The “no step-up” holding in Rev. Rul. 2023-2 and planning alternatives when low-basis property is held by an irrevocable grantor trust
-Structuring to maximize the benefit of SALT workaround payments
-CCA 202309015 and the controversy as to when the sale of a partnership interest may not generate capital gain
-Sorenson and where we stand with Wandry valuation clauses
-ES NPA Holding and the unsuccessful IRS challenge to nontaxability of a profits interest issued in a tiered structure: What was the IRS thinking?
Read More

The Seventh Circuit Issued Its Long-Awaited Decision In Hoops, LP v. Commissioner

The Seventh Circuit issued its long-awaited decision in Hoops, LP v. Commissioner, Docket No. 22-2012 (7th Cir. Aug. 10, 2023), in which it held that a partnership could not deduct deferred compensation due under a non-qualified deferred compensation plan to two NBA players when the deferred compensation liability was assumed by the purchaser of the Memphis Grizzlies NBA basketball team. This result means that the seller’s amount realized on the sale includes the amount of the liability assumption, yet the seller is not entitled to a deduction for the deferred compensation at the time of the sale. At this Fall’s Forum programs, we will be discussing this important case and how to structure a sale of a business where the buyer is assuming a non-qualified deferred compensation liability to avoid this whipsaw.

Registration Is In Full Swing For Our 2023 Tax Forum programs.

Capacity is limited for our in-person programs in Las Vegas and Orlando. Register Now before registrations and rooms fill up.

For those of your who prefer the comfort of your own home/office, please join us for any of the 14 virtual Forum and Fundamentals programs… the first of which kicks-off in two months on October 17th.

We look forward to seeing you… either in person or remotely… very soon!

In the meantime, we are always happy to address your questions related to any passthrough or closely held business matter that comes up in your practice. Please do not hesitate to call us at 800-286-4760 or email either of us.

Share this update with your peers.

Please forward this email to colleagues. They can subscribe to our updates on the Tax Forum website