Four Tiers of Loss Limitations: A Guide to the New Rules for Pass-Through Entities

Course Details

Date

Friday, November 8, 2019

1:00pm – 5:00pm (Registration: 12:30pm)

Location

Ramkota Hotel

800 North Poplar

Casper, WY 82601

307-266-6000

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Field of Study

Taxation

CPE Credit

4 hours CPE credit

Level of Knowledge

Intermediate

Vendor

Surgent & Associates, LLC

Prerequisites

Basic familiarity with loss allowance rules of pass-through entities.

Description

Owners of S corporations and partnerships are subject to numerous limitations on pass-through losses, each with unique rules, applications, and complexities. With the increase in popularity of pass-through business entities, it is essential for CPAs to understand the complexities and interactions of these pass-through loss limitations.

Highlights

  • Tier 1: Basis limitations for S corporation shareholders and partners
  • Tier 2: §465 at-risk limitations for S corporation shareholders and partners, including the impact of debt, indemnities, guarantees, and shareholder/partner agreements
  • Tier 3: §469 passive loss limitations and exceptions to the limitations
  • Tier 4: The new excess business loss limitation of the Tax Cuts and Jobs Act of 2017 (new §461(l))

Objectives

  • Analyze how basis in an ownership interest in a pass-through entity is established
  • Discuss how activity of the entity, distributions, and optional adjustments increase or decrease basis
  • Discuss when basis is “at-risk” under §465, and the resulting loss disallowance and carryforward related to basis that is not at-risk
  • Define passive activities under §469 and exceptions to the passive loss rules
  • Discuss when and how aggregation of activities should be used to avoid the passive loss rules
  • Analyze new §461(l) created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting arryforward
  • Analyze the hierarchy of the loss limitations with examples of the application of the four tiers of losses and how they interact

Designed For

Experienced practitioners who desire a refresher on loss limitiations and an analysis of the new rules.  Inexperienced practitioners who desire to learn the basics of all four pass-through loss limitations and their interactions in one course.

Course Pricing

WYOCPA Member Fee

Applicable if you are a WYOCPA member in good standing.

$165.00
Non-Member Fee

Applicable if you are not a WYOCPA member.

$195.00
Your Price $195.00

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