The purpose of this course is to provide an in-depth discussion of selected advanced-level issues affecting LLCs and LLPs.
- Single-member limited liability companies as an alternative to subsidiaries
- Cancellation of indebtedness: rules and regulations
- 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?
- Material participation rules for LLC members and limited partners: how they affect passive loss issues
- Continuation and termination of an LLC/partnership in the context of a merger or acquisition
- Sales of an LLC Interest -- holding period, and hot asset issues
- Impact of the new tax on investment income on the sale of an interest in a partnership or LLC
- Identify the tax and non-tax advantages and disadvantages of LLCs and partnerships
- Describe how inside and outside basis is affected by liabilities, recourse and nonrecourse
- Discuss the impact of cash and property distributions
- Explain the tax consequences of a sale of an interest and distinguish such consequences from the tax consequences when a partnership or LLC is acquired or merges into another LLC or partnership
- New Feature: Case study to improve advocacy skills before the IRS
Who should take this course:
CPAs with clients using the LLC or LLP structure who need to understand advanced issues, problems, and planning strategies
A basic course in LLCs/partnerships or equivalent knowledge and experience