Complex Tax Provisions in LLC Operating Agreements: Minimum Gain Chargeback, Waterfall Allocations, QIOs
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will examine complex tax clauses in operating agreements to assist tax practitioners in identifying and implementing these key provisions in accordance with partners' expectations and existing regulations.
Outline
- Complex provisions in LLC agreements: an introduction
- Meeting the regulatory safe harbors
- Understanding minimum gain
- DROs vs. qualified income offsets
- Liquidation according to positive capital accounts vs. target capital accounts
- Layer cake allocations and waterfalls
Benefits
The panelist will review these and other key issues:
- Identifying waterfall allocation clauses in LLC agreements
- Calculating target capital account allocations
- Ensuring partnerships meet regulatory safe harbors for allocations
- Analyzing special allocations
Faculty
John T. Alfonsi, CPA
Managing Director
Cendrowski Corporate Advisors
Mr. Alfonsi has 25 years of tax consulting, business valuation, litigation support and forensic accounting experience.... | Read More
Mr. Alfonsi has 25 years of tax consulting, business valuation, litigation support and forensic accounting experience. In the tax planning and consulting arena, he works primarily with partnerships and with private equity, venture capital and hedge funds.
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Joseph C. Mandarino
Partner
Smith Gambrell & Russell
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of... | Read More
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino’s practice also includes representation in tax controversy work. He writes and speaks extensively on a wide range of business, tax and finance topics.
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