See Credit Details Below
Overview
Since the COVID-19 pandemic will prevent us from gathering live in three cities to present Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances 2021, PLI, our program Co-Chairs, and faculty are pleased to present a two-part, five-day partnership tax series in 2021.
Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances 2021 Part One: The Structural Framework of Subchapter K will be presented via live webcast May 10-12, 2021. Tax Planning 2021 Part One will present an in-depth look at the structural framework and essential elements of Subchapter K, an area of the tax law that many believe can be understood only in its totality.
Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances 2021 Part Two: Special Industries and Topics will be presented via live remote webcast June 8-9, 2021. Tax Planning 2021 Part Two will focus on timely advanced and specialized topics, such as distressed partnerships 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 two-part program, emphasis will be given to legislative, regulatory and judicial developments in Subchapter K, including the economic impact of the COVID-19 pandemic, and the impact of the 2017 Tax Act, as well as important partnership transactions, controversies and trends.
What You Will Learn
- Overview of partnership income taxation’s place in the overall U.S. tax regime
- Effects of recent or proposed tax legislation, including the 2017 Tax Act, and pending regulatory proposals
- The benefits and detriments of choosing the partnership form
- Partnership interest basis issues, including allocation of liabilities
- Drafting partnership agreement allocation and distribution provisions
- Formation of partnerships, including joint ventures of operating businesses
- Mergers and divisions
- Audit rules
- International joint venture issues and planning
- Private equity, including passthrough investments
- Hedge fund structures and tax planning for managers and investors
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 foreign. For some of the more advanced topics, the faculty will be joined by panelists from the IRS. 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.
Program Level – Overview
Intended Audience - Law firm and accounting firm professionals, 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