Loss Limitations Analysis: Basis, At-Risk, Passive, and NOLs
Recording of a 110-minute CPE webinar with Q&A
This course will discuss the hierarchy of basis, at-risk, passive activity loss (PAL) limitations, net operating loss (NOL) limitations, and steps to avoid and mitigate the limitation of losses for owners of partnerships and S corporations.
Outline
- Basis
- At-risk limitations
- Passive loss limitations
- Net operating losses
- Section 461(l) excess business loss limitation
- Planning opportunities
Benefits
The panel will review these and other notable issues:
- The appropriate hierarchy for application of loss limitations
- What constitutes amounts at risk for partnerships and S corporations
- How can activities be aggregated to avoid PAL limitations?
- When losses are carried forward, and how are losses applied to different types of income?
Faculty
Matthew L. Roberts, J.D., LL.M.
Partner
Gray Reed
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients... | Read More
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Mr. Roberts brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships and corporations.
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Joshua D. Smeltzer
Partner
Gray Reed
Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his... | Read More
Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his practice on defending taxpayers in all stages of civil and criminal tax proceedings, including sensitive audits and examinations. Mr. Smeltzer frequently represents corporations, complex partnerships, family offices, estates and trusts, and high-net worth individuals. His practice encompasses a variety of industries, with special expertise in real estate, energy, insurance, private equity, digital assets and blockchain technology. Mr. Smeltzer uses his background as a former U.S. Department of Justice lawyer to provide first-hand knowledge when the government is involved in litigation in designing an effective plan to litigate disputes, minimize risks and achieve as many client goals as possible. He has deep litigation and trial experience, both as a private and government lawyer, in controversies ranging from $500,000 to more than $1.5 billion.
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