Chair: James A. Gouwar, Esq., Partner, Clifford Chance, New York, NY
REGISTRATION AND DISTRIBUTION OF MATERIALS
8:30 – 10 a.m., 10:15 a.m. – 12 p.m.
INTRODUCTION, CHOICE OF ENTITY AND FORMATION
Introduction; choice of entity considerations; entity classification and restrictions on partnership status. Formation of a partnership nonrecognition, beginning book and tax capital account and beginning basis; taxable year; methods of accounting.
- Charles R. Bogle, Esq., Partner, Morgan, Lewis & Bockius, New York, NY
- Justin S. Cohen, Esq., Associate, Hughes Hubbard & Reed, New York, NY
10 – 10:15 a.m.
12 – 1 p.m.
1 – 2:30 p.m., 2:45 – 4:30 p.m.
Effect of partnership operations on tax and book capital accounts and basis; special allocations.
- Sean Austin, Esq., Managing Director, KPMG, New York, NY
- Beverly Katz, Esq., Director, Passthroughs Group, Washington National Tax, KPMG, Washington, DC
1 p.m. – 2:30, 2:45 - 4:30
Disguised sales and other partner-partnership transactions.
- Sam Kamyans, Esq., Partner, Allen & Overy
- Monisha Santamaria, Principal, Washington National Tax, KPMG, Washington, DC
3:30 – 4:30 p.m.
Work through a partnership tax return and a sample partnership agreement with emphasis on the tax-sensitive provisions, such as capital account maintenance, book-ups, choice of allocation methods under Section 704(c), allocation and distribution provisions, and liquidation provisions.
- James A. Gouwar, Esq., Partner, Clifford Chance, New York, NY
- Mike Hurwitz, CPA, Partner, BDO, New York, NY
Upon completion of this program, you will have acquired a solid foundation from which to address the intricacies of Subchapter K of the Internal Revenue Code:
- The nature of partnerships and the various legal entities taxed as partnerships
- The relationships between a partnership and its partners, as well as between and among partners themselves
- Approaches to formation including contributions of property and services in exchange for partnership interests, and the classification of those interests
- Partnership operations and reporting with particular emphasis on the basics of distributions to partners and allocation of income and deductions
- Winding down and winding up partnerships, including the withdrawal of individual partners and the transfer of partnership interests
Program Level: Basic • Prerequisite: No Prerequisite