ACTL
SURGENT McCOY'S ADVANCED CRITICAL TAX ISSUES FOR LIMITED LIABILITY COMPANIES AND PARTNERSHIPS

The purpose of this course is to provide an in-depth discussion of selected advanced-level issues affecting LLCs and LLPs. The focus is to analyze the unresolved issues of these emerging business forms.

Major topics include:
  • Single-member limited liability companies as an alternative to subsidiaries
  • How the IRS views members or partners for Social Security purposes
  • Special problems when forming an LLC
  • Debt issues and problems in structuring LLCs and LLPs, including loan guarantee issues, recourse and nonrecourse debt, and the at-risk basis rules
  • Distributions: is it just a disguised sale?
  • Death or retirement of a member or partner -- Understanding the alternatives
  • Step-up in basis issues -- How to make the computations and elections
  • Property transactions between the LLC/LLP and its members or partners -- Inbound and outbound transactions: what to do with built-in gain or loss property
  • Partnership losses: when are they deductible?
  • Continuation and termination in the context of a merger or acquisition
  • Sales of an LLC Interest - holding period, and hot asset issues

Designed for: CPAs with clients using the LLC or LLP structure who need to understand advanced issues, problems, and planning strategies.

Level of knowledge: Advanced

Field of study: Taxes