Introduction:

The taxation of pass-through business entities, such as Subchapter S corporations, partnerships, and limited liability companies, under U.S. federal income taxation is covered in this training program.It focuses on the requirements of Subchapters S and K of the Internal Revenue Code that apply to the creation, management, and dissolution of pass-through organizations, as well as the associated Treasury Regulations and judicial decisions.

Program Objectives:

At the end of this program, the participants will be able to:

Avoid double taxation.
Simplify tax filing processes.
Effectively manage and monitor business income.
Gain expertise in partnership and corporate taxation, or advance LL.M. studies.
Expand their professional practice into business entity taxation.

Targeted Audience

Members of the financial accounting team.
Finance managers and employees in cost and management accounting.
Budget supervisors.
Experienced lawyers.
Financial commitment and participants in the project.
Members of the acquisition team and investment analysts.

Program Outline:

Unit 1:

Partnership Formation:

Partnerships.
Legal Framework.
Special Basis Concepts.
Other Issues.
Nonrecognition Provision.
Basis Determination & Holding Period.

Unit 2:

Partnership Operations:

Income Measurement & Reporting.
Partner’s Distributive Share.
Outside Basis Adjustments.
Partners' Deduction for Qualified Business Income.
Partner Loss Limitations.
Related Transactions.

Unit 3:

Partnership Distributions:

Concepts.
Applications.
Disproportionate Distributions.

Unit 4:

Partnership Sales and Terminations:

Seller.
Buyer.
Special Basis Adjustment.
Other Dispositions.
Partnership Termination.

Unit 5:

Taxation Considerations:

Initial Costs.
Accounting Methods.
Tax Year.
Applications.

Taxation of Pass Through Business Entities