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This three-day program has been designed to ensure that all attendees – from beginners to experts – will benefit. The first two days will present a logical and comprehensive study of the 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 timely advanced and specialized topics, such as the new partnership audit rules and international joint venture issues, and 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.
The faculty will consist of some of the world’s leading experts and senior government officials with special expertise in the transactional aspects of structuring partnerships, joint ventures and other strategic alliances, both domestic and foreign. 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 most sophisticated and current transactional issues.
What You Will Learn
After completing this program, participants will be able to:
- Identify the planning issues that arise when considering the use of a partnership for business or investment
- Draft and review partnership allocation provisions in both allocation- and distribution-driven agreements
- Calculate outside basis
- Issue spot and structure partnership debt workouts and restructuring transactions
- Draft partnership agreements and disclosure documents in the post-TEFRA world
- Understand recurring tax issues in industries that often use partnerships, such as real estate and investment funds
Special Feature: Earn Ethics Credit
Program Level: Overview
Intended Audience: Law firm lawyers, accounting firm and in-house tax professionals, and government attorneys who want to study the intricacies of Subchapter K and the application of partnership taxation to specific industries.
Prerequisites: An interest in exploring the legislative, regulatory and judicial developments in Subchapter K and important partnership transactions, controversies and trends.
Advanced Preparation: None