Practicing Law Institute: Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023

Cristina Arumi will be speaking during PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023, “Partnership Formations and Special Issues – Extracting Value” on 25 April at 3:45 p.m. CDT, 9 May at 3:45 EDT, and 6 June at 3:45 p.m. PDT.

This session will address partnership formation issues, from the “basic” nonrecognition rules to complex issues involving Revenue Ruling 99-5, the “anti-churning” rules of Section 197, and Section 168(k), as well as Section 199A and Section 163(j). After completing this session, participants will be able to:

  • understand the different ways a partnership can be formed and why it may matter;
  • recognize when your entity qualifies for the passthrough regime in Section 199A;
  • use the new Section 163(j) limitation on the deductibility of business interest; and
  • navigate certain partnership-related features of the Section 163(j) limitation on the deductibility of business interest.

The April and May sessions will be presented both in-person and via live webcast, with the June session only available in person in San Francisco, CA.



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