Why You Should Attend
Over the past decade partnerships have emerged as a major form of doing business. Joint ventures between large companies or with start-up or other smaller companies are now an everyday occurrence. Managed fund growth has exploded, as these entities have taken on activities once dominated by the great financial institutions, such as trading, lending and mergers and acquisitions. In addition, partnerships have long been the tried and true form for the holding and operation of real estate and energy related businesses. There are over one hundred publicly traded partnerships that compete with public corporations in the capital markets. As the world economy unites, international business partnerships play an ever increasing role. More than ever before, in-house tax executives, family offices and tax professionals must advise their clients on the opportunities and pitfalls of structuring joint ventures and investments as partnerships or LLCs under Subchapter K of the Internal Revenue Code.
This three-day seminar has been redesigned to ensure that all attendees will benefit, from beginners to experts. The conference will teach and illustrate the partnership tax rules from the birth of the partnership, its operating life and on through its wind down, with an emphasis on practical planning strategies The first two days will present a logical and comprehensive study of the basic framework and many important intricacies of Subchapter K, an area of the tax law that many believe can only be understood in its totality. The third day will focus on industry specific partnership taxation, including oil & gas, hedge funds, private equity funds, and tax credit based partnerships. Throughout this intensive program, emphasis will be given to legislative, regulatory and judicial developments in Subchapter K as well as important partnership transactions, controversies and trends. Speakers from Treasury and the IRS will join a number of the more advanced panels in order to discuss cutting-edge issues.
What You Will Learn & Special Features
- The benefits and detriments of choosing the partnership form
- Avoiding the partnership form for certain strategic alliances
- Partnership interest basis issues, including allocation of liabilities
- Determinations of partners’ distributive shares and the effect of liabilities
- Drafting partnership agreement allocation and distribution provisions
- Partnership and LLC compensatory interests including options, with a government panelist
- Planning under Section 704(c)
- Formation of partnerships, including joint ventures of operating businesses
- “Topside” planning for private equity investments
- Transactions between the partnership and partners, including exit strategies
- Dispositions of partnership interests, partnership distributions and terminations
- Section 754 election planning and special basis adjustments
- Partnership mergers and divisions
- Economic substance, judicial doctrines and ethics issues
- Panel on interesting partnership transactions of the past year
- Session featuring IRS and Treasury representatives on the government perspective on key partnership issues
- International joint venture issues and planning, including a government panelist
- Effects of recent or proposed tax legislation and pending regulatory proposals
For additional information, visit PLI's website.