Partnerships and LLCs involve unique problems that require careful attention. This course covers selected critical tax issues that practitioners need to know when working with partnerships and limited liability companies, with a focus on planning opportunities and pitfalls.
Learning Objectives
• Identify §199A issues for your clients
• Identify and distinguish guaranteed payments and distributive shares
• Understand the relationship between capital account maintenance and outside basis adjustment
• Define various kinds of partnership liabilities and explain the tax consequences of each
Major Topics
• Summary of important provisions of the Tax Cuts and Jobs Act of 2017, specifically including the critical §199A and the final regulations thereunder
• Self-employment tax issues: what you can and cannot do
• Capital accounts: book vs. tax issues
• Determining basis: key issues and technical analysis in calculating basis
• Dealing with debt: recourse, nonrecourse, and why it matters, in particular the possibility of gain upon refinancing
• Guaranteed payments, distributive shares, and draws: understanding the difference because of the different tax consequences
