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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 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 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, including the impact of the 2017 Tax Act, as well as important partnership transactions, controversies and trends.
- 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
- Partnership mergers and divisions
- 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
- New session: Hot Topics in Partnership Tax: The Practitioner’s Perspective
- Panel on interesting partnership transactions of the past year
- Session featuring IRS and Treasury representatives on the government perspective on key partnership issues
The faculty will consist of both inside and outside 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 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.
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