Four Tiers of Loss Limitations: A Guide to the New Rules Webcast [FTL4]
Time: 08:30am-12:00pm
Subject:
TaxationCredit Hours:
4.00Price:
Member: $150.00
Non-member: $225.00
Discussion Leader:
Joseph Nicola, CPA
more info
Joe Nicola is a Tax Partner with more than thirty-five years of experience in public accounting. Joe has experience in many diverse areas of taxation, including the taxation of and planning for individuals, family offices, and various forms of business entities, such as corporations, partnerships, and limited liability companies. Joe is particularly experienced in federal and multi-state tax matters that affect numerous industries and niches, including private equity, investments, natural resources, manufacturing, distribution, high technology, securities, and start-up businesses. He has consulted on technically complex matters, such as retirement planning, succession planning in the context of a family office, securities, partnership and corporate reorganizations and liquidations, and international tax matters. While in public practice, Joe also served for many years as an adjunct member of the faculty with Duquesne University's MBA and Master of Science in Taxation/Accountancy programs, as well as with Robert Morris University's Master of Taxation program. His course load included Corporate Taxation, Advanced Corporate Taxation, Reorganizations (Mergers and Acquisitions), Taxes as a Basis of Managerial Decisions, and Taxation of Derivatives. He is also a published author of CPE/CLE texts and industry articles, and a frequent professional speaker. Mr. Nicola received his BS degree in Business Administration from Robert Morris University and his JD degree from the University of Pittsburgh School of Law.
closeWebsite registration for this course closes on August 23, 2021. To register after this date please contact the society at akcpa@ak.net or 907-562-4334.
Full Description
Four Tiers of Loss Limitations: A Guide to the New Rules for Pass-through Entities Webcast (FTL4)August 24th, 2021
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 Topics Covered:
-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 Objectives:
-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
Designed For: 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.
CPE Credits: 4, Taxation
Level of Knowledge: Intermediate
Prerequisite: Basic familiarity with loss allowance rules of pass-through entities
Acronym: FTL4
Discussion Leader: Joseph Nicola, CPA
