Forum TWENTY-FOURTH ANNUAL PARTNERSHIP, LLC & S CORPORATION TAX PLANNING FORUM

Day One
8:30 AM to 5:00 PM (Luncheon and Presentation 12:00-1:30)*

Structuring Techniques for 2010 and Beyond – A Day of Closely Held Business Planning
The impact of recent tax legislation on closely held business planning, including any carried interest legislation
Forum XXIV’s Top Ten – 2010’s most significant structuring techniques and foot faults (some of which may be covered on day two)
Codification of the economic substance doctrine and its impact on tax planning
“Do-overs” – avoiding pitfalls when rescinding a transaction
G-I Holdings Inc. and §707(a)(2)(B) disguised sales

Issues facing the financially distressed flow-through entity –
  Properly structuring a related party loss-recognition transaction
  Analysis of expected guidance addressing §108(i) COD income deferral elections
  Partnership funding decisions under the expected §108(e)(8) final regulations addressing the contribution of partnership debt to capital
SE tax planning – what to do now as Treasury stirs
Series LLCs under expected Treasury guidance

 
Thursday Evening Networking Dinners

Boston — Legal Sea Foods (September 23)
Atlanta —Pittypat's Porch (October 21)
Chicago — Frankie's Scaloppine (October 28)
Washington, D.C. — Moon Bay (November 11)
San Diego —Osteria Panevino (December 9)

Interact with the faculty and fellow attendees and spend an informal evening sharing war stories

 

Day Two
8:00 AM to 3:45 PM (Lunch on your own 11:45-12:45)

Hot Partnership and LLC Topics for 2010
Family limited partnership update, including an analysis of any anti-discounting legislation and recent present interest activity
Notice 2009-70 and hot §704(c) allocation issues to consider
§469 passive loss developments, including new reporting requirements and expected Treasury guidance regarding the material participation of LLC members
At-risk rule developments and analysis of expected guidance on partner guarantees
A potpourri of recent partnership and LLC developments

Hot S Corporation Topics for 2010
Hidden traps when dealing with ESBTs and QSSTs
Integrating §338(h)(10) with contingent purchase price installment sales

Structuring S corporation back-to-back loans under expected Treasury guidance
A potpourri of recent S corporation developments

* Maui presentation will be held on three days from 7:30 a.m. to 12:30 p.m., without a luncheon.

All faculty members are scheduled to participate in each session, utilizing extensive case studies and examples to illustrate the issues to be discussed. An analysis of recent legislation and the latest cases, regulations and rulings will be integrated into each session. Program content and timing are based upon the current status of the law and may be modified if warranted by new developments.