Many of our clients are pass-through entities, for which many of the general business strategies are subject to additional limitations. This course will help CPAs understand the complexities and interactions of these pass-through loss limitations, as well as the special concerns and techniques the practitioner needs to deliver successful tax planning strategies in this market.
DESIGNED FOR
All practitioners who do tax planning for their clients or companies, as well as those who want to learn about the four pass-through loss limitations, their interactions, and the new rules.
BENEFITS
- Analyze how basis in an ownership interest in a pass-through entity is established, how various factors increase or decrease basis, and how strategies related to tax planning are modified for pass-throughs
- Analyze the hierarchy of the loss limitations with examples of the application of the four tiers of losses and how they interact
- Understand the special problems when transactions involve the business, its investors, and related businesses and individuals
- Analyze new §461(l) created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting carryforward
HIGHLIGHTS
- Basis limitations for S corporation shareholders and partners
- §465 at-risk limitations for S corporation shareholders and partners, including the impact of debt, indemnities, guarantees, and shareholder/partner agreements
- §469 passive loss limitations and exceptions to the limitations
- The new excess business loss limitation of the Tax Cuts and Jobs Act of 2017 (new §461(l))
- Relevant changes from The Tax Cuts and Jobs Act of 2017 including detailed treatment of §199A
- Basis planning
- Related party transactions
- Benefits of income splitting and shifting with family
COURSE LEVEL
Basic
PREREQUISITES
Experience with business clients and basic familiarity with loss allowance rules of pass-through entities.
ADVANCE PREPARATION
None