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Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances

Speaking Engagements

Loeb & Loeb partner Terence Cuff will present at PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances.

  • Review basic concepts then tackle more complex issues
  • Explore the benefits and detriments of choosing the partnership form
  • Hear speakers from Treasury and the IRS on cutting-edge issues
  • including economic substance, anti-abuse rules, tax shelters, preparer penalties and related matters
  • Examine the tiered partnership setting
  • Review pending regulatory proposals
  • Understand special partnership tax accounting rules
  • Hear from inside tax counsel on forming and operating a joint venture

Agenda Highlight

Thursday, June 12, 10:30 AM - Practical Implications of Section 704(c) for Negotiating a Partnership Agreement - presented by Loeb partner Terence Cuff
Book/tax disparities; statutory framework; mechanics of Section 704(c) and reverse
Section 704(c) allocations; final and temporary regulations; the traditional method; ceiling
limitation principles; traditional method with curative allocations; remedial allocation method;
other reasonable allocation methods; anti-abuse principles; planning concepts; effect of
2004 Jobs Act amendments, including allocations with respect to built-in loss property.