VIRTUAL ONLY: Four Tiers of Loss Limitations: A Guide to the New Rules for 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 carryforward 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 limitations 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.



Leaders

Curtis Quickel

Curtis is an individual practitioner in Fayetteville, Arkansas. Since 1998, he has traveled the US teaching Continuing Professional Education courses for the AICPA and others. Before establishing his own practice, he worked several years in industry as a Corporate Controller. After 9/11 Curtis spend 9 years on Active Duty with the US Army completing three combat tours to Afghanistan, Iraq and Kuwait. Curt retired as a Lieutenant Colonel in 2013 with a total of 33 years of Active and Reserve service. He is a Past President of the Central Chapter of the Arkansas Society of CPAs and Past Chairman of the Industry and Commerce Committee. Curt is a past recipient of the Arkansas Society of CPAs Outstanding CPA in Government Award.