TEI partnership seminar an overwhelming success: April 17-19, 2002 * Chicago, Illinois. (Recent Activities).
TEI's Federal Tax Committee assembled one of the finest possible faculties, allowing participants to progress rapidly from an elementary understanding of the partnership rules to the cutting edge of complex current transactional issues.
On Day One, the program covered such fundamental issues as the benefits and detriments of choosing the partnership form, formation issues, special partnership tax accounting rules, and important negotiating points for drafting partnership agreements. Experienced practitioners then examined certain planning transactions and rules through the prism of the partnership rules, including disguised sales and like-kind exchanges. Other sessions discussed surviving partnership audits and strategies for entering and exiting a partnership.
Day Two focused on a number of unique partnership tax planning and transactional issues, beginning with an overview of "thinking outside the corporate box and inside the partnership triangle," partnership mergers and divisions, and a review of techniques for compensating partners, including guaranteed payments and emerging issues in the use of options and other forms of equity. The afternoon sessions focused on partnership basis and liability allocation issues, concluding with a session devoted to state and local planning and controversies.
On Day Three, the emphasis shifted to international tax issues, including the use of hybrids, check-the-box rules, in the context of forming and operating foreign joint ventures, and the traps and opportunities surrounding the Subpart F rule. Other sessions concentrated on tax planning for joint ventures, featuring foreign tax credit aggregation and disaggregation, tax treaty withholding and reporting requirements for partnerships, and developments in partnership reporting rules.
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|Date:||May 1, 2002|
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