22WS-1365: Surgent's Four Tiers of Loss Limitations: A Guide to the Rules for Pass-Through Entities (Webinar)
If you have questions about this event, please call us at 952-831-2707.
Tuesday, January 17, 2023
12:30pm - 4:00pm Central Time
4 CPE (4 technical) | 4 IRS CE
Owners of S Corporations and partnerships are subject to numerous limitations on pass-through losses, each with unique rules, applications, and complexities. With the increase in popularity of pass-through business entities, it is essential for CPAs to understand the complexities and interactions of these pass-through loss limitations.
Major subjects
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Tier 1: Basis limitations for S Corporation shareholders and partners
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Tier 2: Section 465 at-risk limitations for S Corporation shareholders and partners, including the impact of debt, indemnities, guarantees, and shareholder/partner agreements
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Tier 3: Section 469 passive loss limitations and exceptions to the limitations
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Tier 4: The new excess business loss limitation of the Tax Cuts and Jobs Act of 2017 (new Section 461(l)) and a look into possible changes to the deduction in the future
Learning objective(s)
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Analyze how basis in an ownership interest in a pass-through entity is established
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Discuss how activity of the entity, distributions, and optional adjustments increase or decrease basis
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Discuss when basis is "at-risk" under Section 465, and the resulting loss disallowance and carryforward related to basis that is not at-risk
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Define passive activities under Section 469 and exceptions to the passive loss rules
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Discuss when and how aggregation of activities should be used to avoid the passive loss rules
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Analyze new Section 461(l) created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting carryforward
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Analyze the hierarchy of the loss limitations with examples of the application of the four tiers of losses and how they interact
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Use case studies to reinforce the learning objectives
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.
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