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PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2011

Loeb & Loeb LLP is pleased to announce that partner Terence F. Cuff will be speaking at Practising Law Institutes Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2011 seminar.

From the program website:

This three-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, 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.

The faculty will consist of both inside and outside tax counsel with special expertise in the transactional aspects of structuring partnerships, joint ventures and other strategic alliances, both domestic and foreign. For some of the more advanced topics, the faculty will be joined by panelists from the IRS and Treasury. Many of the faculty have significant teaching experience and will adopt an approach designed to enable attendees to progress rapidly from an elementary understanding of the rules to the cutting-edge of the most complex of current transactional issues.

Selected Agenda

Wednesday, June 15, 2011
9:00am – 10:00am - Partnership Basis Issues Including Allocating Liabilities Among Partners

Relevance of basis in partnership interest; equality of inside and outside basis; Sections 705 and 752; partnership interest distinguished from partner’s capital account; effects of contributions; effects of liabilities; effects of income and loss; effects of distributions; ordering and timing rules; allocation schemes for recourse and nonrecourse liabilities; bottom-dollar guarantees; capital account deficit restoration obligations; capital contribution obligations; final regulations for DREs; contingent liabilities and “Son of Boss” regulations; recent Notices.

Terence F. Cuff, Loeb & Loeb LLP

Wednesday, June 15, 2011
2:30pm – 3:45pm - Implications of Section 704(c) for Negotiating a Partnership Agreement

Book/tax disparities; statutory framework; mechanics of Section 704(c) and reverse Section 704(c) allocations; final and proposed regulations; the traditional method; ceiling limitation principles; traditional method with curative allocations; remedial allocation method; other reasonable allocation methods; anti-abuse principles; final Section 704(c) anti-abuse regulations; Section 704(c) in tiered structures and in mergers and divisions; Notice 2009-70; remedials and related parties; planning concepts.

Terence F. Cuff, Loeb & Loeb LLP
Robert J. Crnkovich, Department of the Treasury
Kevin Richards, Ernst & Young LLP