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

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?

Forum XXXVII’s Top Ten: 2023’s Most Significant Flow-Through Issues and Avoidance of Foot Faults

Emerging Partnership and LLC Topics For 2023 and Beyond

=2023’s §704(b)/§704(c)/§752 structuring issues and techniques
-Effectively structuring related-party installment sales
-The differing “aggregation” concepts under §199A, §465, §469 and §1411 and when they make a difference
-TAM 202229036 and integrating §469 material participation and significant participation standards
-Exiting the personal service firm: installment sale or serial redemption?
-The impact of stock forfeitures on §1202 stock eligibility
-Structuring a “Lender Bagel” transaction to deduct investment management fees
-Alternate approaches to solve a missed §754 election

Hot S Corporation Topics for 2023 and Beyond

-Refining the F Reorganization and avoiding traps for the unwary
-Cecil and the current thought process on tax-affecting the value of gifts of S corporation stock
-Developments concerning the breadth of automatic relief under Rev. Proc. 2022-19 for “defective” S elections
-The §108(e)(5) purchase-money basis reduction exception to COD income recognition – how far does it go?

Chuck Levun and Michael Cohen will entertain questions from attendees throughout the virtual programs (which include scheduled live Q&A sessions) and during and after the in-person programs.



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