This seminar is designed for attorneys, accountants, controllers, enrolled agents, CFOs, business owners and managers, presidents, financial planners, real estate professionals and lenders.
This one-day seminar offers insight and strategies for addressing issues that arise when entities make various distributions. Discussions will highlight the latest tax strategies used when structuring distributions from different entities. This seminar will help you avoid many of the common mistakes made when structuring these complex transactions, and allow you to better identify potential problems that arise in the distribution planning arena. This seminar will bring you up to date with all the latest tax law changes.
8:30 a.m. - 10:10 a.m.
I. Distributions From Partnerships
A. The General Rules
1. The Treatment To The Recipient Partner Of Cash Or Property
2. The Treatment To The Partnership Of Distributions
3. The Adjusted Basis Of Property Received In A Distribution
B. “Mixing Bowl” Transactions
1. The Treatment To The Partner Contributing Appreciated Or Depreciated Property To The Partnership [Code Section 704(c)(1)(B)]
2. The Treatment To The Partner Receiving Property (Code Section 737)
C. The Distribution Of Marketable Securities [Code Section 731(c)]
D. Disguised Sale Transactions [Code Section 707(a)(2)]
10:10 a.m. - 10:20 a.m.
10:20 a.m. - 12:00 p.m.
II. Distributions From C Corporations
A. Non-Liquidating Distributions Of Property From C Corporations
1. Taxation Of The Corporation
2. Taxation Of Individual Shareholders
3. Taxation Of Corporate Shareholders
B. Redemptions Of Stock
1. Not Essentially Equivalent To A Dividend
2. Substantially Disproportionate Redemptions
3. Complete Termination Of A Shareholder’s Interest
4. Partial Liquidations
C. Redemptions To Pay Estate Taxes
D. Redemptions Through Related Corporations
E. Distributions Of Stock And Stock Rights
F. “306” Stock
G. Liquidating Distributions
1. Corporate Shareholders
2. Individual Shareholders
H. Miscellaneous Other Provisions
12:00 p.m. - 1:00 p.m.
Lunch (On Your Own)
1:00 p.m. - 2:40 p.m.
III. S Corporation Distributions
A. Impact On S Corporation Election
B. Basis Electing Small Business Trusts-Treatment
C. Qualified S Corporation Subsidiary Election
D. Distributions From S Corporations With Earning And Profits
E. Distributions From S Corporations With No Earnings And Profits
F. Accumulated Adjustment Account
G. Election To Distribute Earnings And Profits
H. Ordering Rules
I. Basis Issues
J. Property Distributions
K. Post Termination Transition Period
2:40 p.m. - 2:50 p.m.
2:50 p.m. - 4:30 p.m.
IV. Cutting Edge Techniques And Special Problems
A. Issuance Of “Profits Interest” Solves Many Problems
B. Multi-Tiered Disregarded Entities
C. Electing Small Business Trust Benefits (“ESBT III”)
D. Combining A Family Limited Partnership Or A Family Limited Liability Company And An IRA To Lower Estate Taxes
E. Combining A Charitable Lead Trust And A Family Limited Partnership Or A Family Limited Liability Company To Lower Estate Taxes
F. LLC S Corps, The Wave Of The Future?
G. Sale Of LLC/Pship Interest In Lieu Of Sale Of Underlying Real Estate Asset (Ohio And Federal Benefits And Drawbacks)
H. Tax Traps For The Unwary