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PRODID://NDCP//487691
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DTSTART:20261008T130000Z
DTEND:20261008T210000Z
UID:487691
SUMMARY:Surgent’s Advanced Critical Tax Issues for Limited Liability Companies and Partnerships (ACTL)
LOCATION:Webinar
DESCRIPTION:Surgent’s Advanced Critical Tax Issues for Limited Liability Companies and Partnerships (ACTL)\n\n10/08/26 08:00 AM CST\n - 10/08/26 04:00 PM CST\Description:\nThe purpose of this course is to provide an in-depth discussion of selected advanced-level issues affecting LLCs and LLPs.Objectives:
 Identify tax and nontax advantages and disadvantages of LLCs and partnerships
 Describe how inside and outside basis is affected by liabilities, recourse and nonrecourse
 Discuss the impact of cash and property distributions
 Explain the tax consequences of a sale of an interest and distinguish such consequences from the tax consequences when a partnership or LLC is acquired or merges into another LLC or partnership
 Complete a case study to improve advocacy skills before the IRS
 Presenters:Sue Smith, CPAField of Study:Taxes (8)Major Topics:
 Applicable provisions of the One Big Beautiful Bill Act (OBBBA)
 Single-member limited liability companies as an alternative to subsidiaries
 Cancellation of indebtedness rules and regulations
 How the IRS views members or partners for Social Security purposes
 Special problems when forming an LLC
 Debt issues and problems in structuring LLCs and LLPs, including loan guarantee issues, recourse and nonrecourse debt, the at-risk basis rules, and new regulations restricting bottom-dollar guarantees
 Distribution or a disguised sale? New regulations eliminate certain tax-deferred leveraged partnership transactions
 Death or retirement of a member or partner – understanding the alternatives
 Step-up in basis issues – how to make the computations and elections
 Property transactions between the LLC/LLP and its members or partners – what to do with built-in gain or loss property
 When are partnership losses deductible?
 Material participation rules for LLC members and limited partners and how they affect passive loss issues
 Continuation and termination of an LLC/partnership in the context of a merger or acquisition
 Sales of an LLC interest – holding period and hot asset issues
 Impact of the tax on investment income on the sale of an interest in a partnership or LLC
 Repeal of the technical termination of partnership provision
 Impact of Soroban Capital Partners LP, 161 TC No.12
 NEW: The IRS removes recently finalized regulations identifying certain partnership basis shifting transactions as transactions of interest (see Chapter 2)
 \Location:\nWebinar\n\n,
X-ALT-DESC;FMTTYPE=text/html:Surgent’s Advanced Critical Tax Issues for Limited Liability Companies and Partnerships (ACTL)<br /><br />10/08/26 08:00 AM CST - 10/08/26 04:00 PM CST<br />Description:<br />The purpose of this course is to provide an in-depth discussion of selected advanced-level issues affecting LLCs and LLPs.<br><br><b>Objectives:</b><br><ul>
    <li>Identify tax and nontax advantages and disadvantages of&nbsp;LLCs and partnerships </li>
    <li>Describe how inside and outside basis is affected by liabilities, recourse and nonrecourse </li>
    <li>Discuss the impact of cash and property distributions</li>
    <li>Explain the tax consequences of a sale of an interest and distinguish such consequences from the tax consequences when a partnership or LLC is acquired or merges into another LLC or partnership</li>
    <li>Complete a case study to improve advocacy skills before the IRS</li>
</ul><br><b>Presenters:</b><br>Sue Smith, CPA<br><br><b>Field of Study:</b><br>Taxes (8)<br><br><b>Major Topics:</b><br><ul>
    <li>Applicable provisions of the One Big Beautiful Bill Act (OBBBA)</li>
    <li>Single-member limited liability companies as an alternative to subsidiaries </li>
    <li>Cancellation of indebtedness rules and regulations </li>
    <li>How the IRS views members or partners for Social Security purposes </li>
    <li>Special problems when forming an LLC </li>
    <li>Debt issues and problems in structuring LLCs and LLPs, including loan guarantee issues, recourse and nonrecourse debt, the at-risk basis rules, and new regulations restricting bottom-dollar guarantees</li>
    <li>Distribution or a disguised sale? New regulations eliminate certain tax-deferred leveraged partnership transactions</li>
    <li>Death or retirement of a member or partner&nbsp;&ndash; understanding the alternatives </li>
    <li>Step-up in basis issues &ndash; how to make the computations and elections </li>
    <li>Property transactions between the LLC/LLP and its members or partners&nbsp;&ndash; what to do with built-in gain or loss property </li>
    <li>When are partnership losses deductible?</li>
    <li>Material participation rules for LLC members and limited partners and how they affect passive loss issues </li>
    <li>Continuation and termination of an LLC/partnership in the context&nbsp;of a merger or acquisition </li>
    <li>Sales of an LLC interest&nbsp;&ndash; holding period and hot asset issues </li>
    <li>Impact of the tax on investment income on the sale of an interest in a partnership or LLC</li>
    <li>Repeal of the technical termination of partnership provision</li>
    <li>Impact of Soroban Capital Partners LP, 161 TC No.12</li>
    <li>NEW: The IRS removes recently finalized regulations identifying certain partnership basis shifting transactions as transactions of interest (see Chapter 2)</li>
</ul><br />Location:<br />Webinar<br /><br />,  
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