Thirty-Seventh Annual Partnership, LLC & S Corporation Tax Planning Forum®


This program is presented in a transactional format, so the faculty members will utilize practical 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. (Some of the program may not be covered orally.)

The 2023 program will be finalized in Spring 2023 and will be updated as warranted by new developments; however, the program is expected to include:

Structuring Techniques for 2023 and Beyond – An In-Depth Look at Closely Held Business Planning

Forum XXXVII’s Top Ten: 2023’s Most Significant Flow-Through Issues and Avoidance of Foot Faults

Emerging Partnership and LLC Topics For 2023 and Beyond

  • 2023’s §704(b)/§704(c)/§752 structuring issues and techniques
  • Maximizing the benefit of SALT workaround payments
  • Soroban and other §1402(a)(13) SE tax developments
  • The differing “aggregation” concepts under §199A, §465, §469 and §1411 and when they make a difference
  • When is a QIO triggered and the professional community’s reaction to Clark Raymond
  • TAM 202229036 and integrating §469 material participation and significant participation standards
  • Avoiding the BBA rules for “known” K-1 reporting errors

Hot S Corporation Topics for 2023 and Beyond

  • Refining the F Reorganization and avoiding traps for the unwary
  • The developing thought process on the breadth of automatic relief under Rev. Proc. 2022-19 for inadvertent S corporation ineligibility and terminations
  • The §108(e)(5) purchase-money basis reduction exception to COD income recognition – how far does it go?

Chuck, Michael and Daniel will entertain questions from attendees throughout the virtual programs (which include scheduled live Q&A sessions) and during and after the in-person programs.

Program materials and presentations will provide information relating to the covered subject matter. None of the presenters, authors or publisher will be rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional adviser be engaged.

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