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

From the Practising Law Institute site:
Joint ventures between large companies or with start up or other smaller companies are now an everyday occurrence. Partnerships have long been the tried and true format for the holding and operation of real estate, and, since the 1981 Act, for the conduct of closely-held business operations. Further, the increase in the number of joint ventures to develop large-scale projects and innovative concepts, the rise of the limited liability company, the promulgation of the final Check-the-Box regulations, and the increasing use of hybrids that have fueled an explosion of tax planning opportunities have led many companies, both large and small, to focus on the partnership form or the LLC form for structuring subsidiary operations and foreign operations. More than ever before, corporate tax executives find they must advise senior management, and outside counsel find they 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 two day seminar will trace the partnership tax rules from the birth of the partnership through its operating life, with emphasis on tax issues and planning strategies and opportunities, and then, since for one reason or another such ventures frequently unwind either before or after satisfying their purpose, will focus on exit strategies and tax planning possibilities in unwinding. Some of the sessions on the first day are intended to serve as a review of basics.

Special attention will also be given to planning under recently finalized sets of regulations and proposed regulations and to changes wrought by recent legislation and legislative proposals. Speakers from Treasury and the IRS will be joining a number of the more advanced panels in order to discuss cutting-edge issues. This will include a panel on anti-abuse rules, tax shelters, recent tax shelter cases and legislation, attorney-client privilege and related matters. Finally, the entire afternoon of the second day will be committed to international joint venture tax planning including the use of hybrids and, therefore, is intended to be quite advanced.

Agenda Highlight

At 7:30 AM on Friday, June 15, Loeb Partner Terence Cuff will participate in the continental breakfast discussion "Interesting Partnership Transactions of the Past Year, Current Hot Topics and "Questions and Answers."

For a full agenda information, please visit the Practising Law Institute site.