146 | OSCPA Live | October 25
Four Tiers of Loss Limitations: A Guide to the Rules for Pass-Through Entities
Tuesday, October 25, 2022 8:30am - 12:00pm
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.
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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 Section 465, and the resulting loss disallowance and carryforward related to basis that is not at-risk Define passive activities under Section 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 Use case studies to reinforce the learning objectives
- Edgar Gee (view bio)
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.
Tier 1: Basis limitations for S corporation shareholders and partners Tier 2: Section 465 at-risk limitations for S corporation shareholders and partners, including the impact of debt, indemnities, guarantees, and shareholder/partner agreements Tier 3: Section 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 Section 461(l)) and a look into possible changes to the deduction in the future
Edgar Gee, CPA, MBA, is a local firm practitioner with over 35 years of professional experience. He works closely with small businesses in areas of auditing, tax planning, IRS representation and litigation support services and business valuations. A noted author, Mr. Gee has published articles in the Tax Advisor relating to the largest independent contractor case against the IRS in U.S. history. He testified before the U.S. House of Representatives Subcommittee on the Oversight of IRS Activities in 1996. He is co-author of PPC's Guide to Worker Classification. Winner of the Max Block Award by NYSSCPAs for Distinguished Article of the Year 2000, "Independent Contractor or Employee: How the Process Works Today," Mr. Gee speaks nationally to many professional organizations. He was past president of the Knoxville Chapter of the Tennessee Society of Certified Public Accountants. He was the recipient of the Discussion Leader of the Year award from the Tennessee Society of CPAs in 2001.