Inadequate Tax Basis: Leveraging Basis Rules for S Corporations
Analyzing Guaranteed Loans, Incorporated Pocketbook Theory, and Back-to-Back Loans
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This course will provide tax counsel and advisers with techniques to overcome challenges associated with inadequate basis in S corporations. The panel will discuss IRS regulations that provide resolution to some of the most confusing areas of inadequate basis.
Outline
- Overview of final IRS regulations
- Guaranteed loans to S corporation
- Incorporated pocketbook theory
- Back-to-back loans
Benefits
The panel will review these and other key issues:
- How have the IRS’ final regulations addressed the inadequate basis issues that S corporations face? How must counsel leverage these regulations?
- What techniques are available to S corporations to maximize recognition of economic losses?
- How must counsel navigate confusing and inconsistent legal precedent involving the use of guaranteed loans, back-to-back loans and the incorporated pocketbook theory?
Faculty
Robert S. Barnett, JD, MS (Taxation), CPA
Partner
Capell Barnett Matalon & Schoenfeld
Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and... | Read More
Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and partnership law and charitable planning. His experience includes surrogate’s court practice, tax dispute resolution in both federal and state jurisdictions, and tax court representation. Mr. Barnett frequently assists clients in structuring financial transactions and charitable gifts. His articles and lectures encompass a wide variety of topics, including business succession, estate planning, generation-skipping, stock options, effective strategies for removing tax liens, proper utilization of the marital deduction and utilization of partnership elections.
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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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Albert Dumaual
Atty
Capell Barnett Matalon & Schoenfeld
Mr. Dumaual’s areas of practice focus primarily on tax and estate planning. He received his LL.M. in... | Read More
Mr. Dumaual’s areas of practice focus primarily on tax and estate planning. He received his LL.M. in Taxation from the NYU School of Law and his Juris Doctor from Touro College Jacob D. Fuchsberg Law Center, where he graduated cum laude.
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