Overview

Why You Should Attend
This three-day seminar has been designed to ensure that all attendees will benefit, from beginners to experts. The first two days will present a logical and comprehensive study of the basic framework and many important intricacies of Subchapter K, an area of the tax law that many believe can be understood only in its totality. The third day will focus on the application of partnership taxation to specific industries, including oil and gas, hedge funds and private equity funds. Throughout this intensive program, emphasis will be given to legislative, regulatory and judicial developments in Subchapter K, as well as important partnership transactions, controversies and trends.  Speakers from Treasury and the IRS will join a number of the more advanced panels in order to discuss cutting-edge issues.

What You Will Learn & Special Features
• Overview of partnership income taxation’s place in the overall U.S. tax regime
• The benefits and detriments of choosing the partnership form
• Partnership interest basis issues, including allocation of liabilities
• Advanced topics in joint venture formations
• Partnership mergers and divisions
• Troubled partnerships
• Panel on interesting partnership transactions of the past year
• Session featuring IRS and Treasury representatives on the government perspective on key partnership issues
• Partnership audit rules
• International joint venture issues and planning
• Private equity passthrough investments
• Hedge fund structures and tax planning for managers and investors
• Publicly traded partnerships and the rules of Section 7704
• Economic substance, judicial doctrines and ethics issues
• Effects of recent or proposed tax legislation and pending regulatory proposals

The faculty will consist of tax counsel with special expertise in the transactional aspects of structuring partnerships, joint ventures and other strategic alliances, both domestic and international. For some of the more advanced topics, the faculty will be joined by panelists from the IRS and Treasury. Many of the faculty have significant teaching experience and will adopt an approach designed to enable attendees to progress rapidly from an elementary understanding of the rules to the cutting-edge of the most complex of current transactional issues. 

Credit Details