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
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.