Loeb & Loeb LLP is pleased to announce that Terence F. Cuff will be speaking at the Practising Law Institute seminar, "Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2012."
From the program website:
Joint ventures between large companies or with start-up or other smaller companies are now an everyday occurrence. 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 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 either before or after satisfying their purpose, will focus on exit strategies and tax planning possibilities in unwinding.
Wednesday, June 13, 2012
1:45PM - 2:45PM - 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; Notice 2009-70; remedials and related parties; planning concepts.
Terence F. Cuff, Loeb & Loeb LLP
Andrea Macintosh Whiteway, McDermott Will & Emery LLP
For more information, including how to register, please see the Practising Law Institute website.