Loss Limitations Analysis: Basis, At-Risk, Passive, and NOLs
A live 110-minute CPE webinar with interactive 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.
CloseJoshua D. Smeltzer
Partner
Gray Reed
Mr. Smeltzer is a tax litigator defending clients in tax audits, tax appeals, and litigation in Federal District Court,... | Read More
Mr. Smeltzer is a tax litigator defending clients in tax audits, tax appeals, and litigation in Federal District Court, U.S. Tax Court, the U.S. Court of Federal Claims, and tax issues in U.S. Bankruptcy Court. His previous work as a litigator for the U.S. Department of Justice provides him with first-hand knowledge of how government lawyers build and litigate tax cases. Based on his impressive track record at the Department of Justice, Mr. Smeltzer received the agency’s Outstanding Trial Attorney Award seven times. He also has deep tax litigation experience in federal court, both as a private and government lawyer.
Mr. Smeltzer represents individuals, corporations, partnerships, and estates in a variety of tax issues involving tax reporting for cryptocurrency and foreign bank accounts, captive insurance arrangements, investments in conservation easements, charitable donations, a variety of tax deduction and tax credit disputes, as well as various transactions involving cryptocurrency and blockchain technology. He is often consulted on tax issues arising from significant financial events, such as large financial transactions, litigation settlements, transfers of assets to family limited partnerships or other entities, and tax issues surrounding the sale of business assets or stock.
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CPE On-Demand