21WS-1153: Surgent's Four Tiers of Loss Limitations: A Guide to the New Rules for Pass-through Entities (Webinar)

Description

Who should take this program?

Experienced practitioners who desire a refresher on loss limitations and an analysis of the new rules. Inexperienced practitioners who desire to learn the basics of all four pass-through loss limitations and their interactions in one course.

Major subjects

• Tier 1: Basis limitations for S corporation shareholders and partners
• Tier 2: Section 465 at-risk limitations for S corporation shareholders and partners, including the impact of debt, indemnities, guarantees, and shareholder/partner agreements
• Tier 3: Section 469 passive loss limitations and exceptions to the limitations
• Tier 4: The new excess business loss limitation of the Tax Cuts and Jobs Act of 2017 (new section 461(l))

Learning objective(s)

• Analyze how basis in an ownership interest in a pass-through entity is established
• Discuss how activity of the entity, distributions, and optional adjustments increase or decrease basis
• Discuss when basis is "at-risk" under section 465, and the resulting loss disallowance and carryforward related to basis that is not at-risk
• Define passive activities under section 469 and exceptions to the passive loss rules
• Discuss when and how aggregation of activities should be used to avoid the passive loss rules
• Analyze new §461(l) created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting carryforward
• Analyze the hierarchy of the loss limitations with examples of the application of the four tiers of losses and how they interact