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
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