LCLL
SURGENT McCOY'S CASE STUDIES
IN THE LIFE CYCLE OF A LIMITED LIABILITY COMPANY

This course allows participants to use one continuous sample case to apply federal tax rules to their client's limited liability companies. The case starts with a sole proprietor and follows the business owner through the formation decision, LLC taxation election issues, pre-contribution appreciation in assets, basis implications of recourse and nonrecourse debt, special allocations of income and deductions, basis step-up under §754 on transfer of an ownership interest, self-employment tax issues, and ends with the termination/liquidation of the LLC. Participants will be able to understand tax saving and planning opportunities during the entire life cycle of a typical LLC.

Major topics include:

  • Complete coverage of The Small Business and Work Opportunity Tax Act of 2007
  • Follow one case study from the organization decision, through pre-contribution issues, debt/basis rules, special allocations, step-up in basis rules, self-employment issues and final termination/liquidation
  • Comparison of LLCs with other entity choices
  • Formation issues including §704(c) precontribution appreciated assets
  • Treatment of recourse versus non-recourse debt basis
  • Understanding "substantial economic effect" and special allocations
  • Proper handling of fringe benefits on Form 1065
  • IRS guidance on self-employment tax for partners in a partnership and members of LLCs and LLPs
  • Calculate basis limitations and its implication on each partner's own tax return
  • New regulations for handling basis step ups under §754 elections
  • Partnership distributions - current or liquidating, cash or property
  • Termination/liquidation of an LLC

Designed for: Experienced CPAs desiring a comprehensive case approach to understand reasonably complex limited liability company issues and problems. Also, CPAs who want a comprehensive, intermediate-level limited liability company practice manual.

Level of knowledge: Intermediate

Field of study: Taxes