The New Section 199A Qualified Business Deduction: Opportunities and Stumbling Blocks for Your Business
Overview:
The Tax Cut and Jobs Act (TCJA), passed on December 22, 2017, has added Section 199A to the Internal Revenue Code. The new provision allows a Qualified Business Income (QBI) deduction of up to 20% to owners of Pass-Through entities. Section 199A offers significant benefits to businesses since it can decrease the business income tax rate to 29.6% from 37%. It’s critical for companies to implement tax planning strategies that would effectively optimize the deduction.
In this LIVE Webcast, a panel of distinguished professionals and thought leaders will help firms understand the important aspects of Section 199A. They will provide an in-depth discussion of the benefits and challenges companies may face in taking advantage of this deduction. Speakers will also offer best practices in developing and implementing tax planning strategies in light of the new provision.
Key topics include:
- New Section 199A Qualified Business Deduction – An Overview
- Opportunities for Businesses
- Potential Risks and Pitfalls
- Managing Legal and Regulatory Challenges
- Best Tax Planning Strategies
Agenda:
Douglas W. Schwartz, Partner
Nossaman LLP
- What considerations are there in drafting or updating our partnership/ LLC operating/ S corporation shareholder agreements in order to maximize the benefit of the 199A deduction to owners?
- What structuring options are there for a business with a component (e.g. consulting, health, legal) subject to the 199A phase-outs?
- What considerations are there for “reasonable compensation” for S corporations and “guaranteed payments” for LLCs/ partnerships?
Joshua R. Lake, Attorney
Seyfarth Shaw LLP
- Choice of entity considerations in light of Section 199A (this makes sense after the background and operation of the section has been discussed)
- Section 199A issues relating to real estate investment trusts (REITs)
- The Section 6662 accuracy-related penalty special rule for taxpayers claiming a Section 199A deduction.
Louis Vlahos, Partner
Farrell Fritz, P.C.
- How will it be applied to the income/gain realized on the sale of a business?
- Will it make a difference to otherwise qualifying pass-thru entities that also have foreign corporate subsidiaries?
- Should partnerships/LLCs forego paying guaranteed payments to those partners/members who render meaningful services?
- Will new businesses that are specified trade or businesses be treated differently than existing STBs in that the former may be able to split up various functions at inception while the IRS has intimidated that the latter will not be allowed to spin-off off such functions?
- You’ve decided to convert from one tax entity to another – what are the consequences?
Who Should Attend:
- Tax Executives and Directors
- Tax Attorneys
- Tax Preparers
- Tax Advisers
- Tax Compliance Officers
- Tax Accountants
- Business Executives
- Public and Private Companies
- Other Related/Interested Professionals and Organizations
Douglas Schwartz, in his 30-plus years of practice, has specialized in tax matters affecting personal, business, and other planning for …
Mr. Lake is an associate in Seyfarth Shaw LLP's Tax and Corporate practice groups, based in the firm’s New York …
Louis Vlahos is a partner and leads the firm’s tax practice. Mr. Vlahos has extensive experience in corporate, individual and …
Course Level:
Intermediate
Advance Preparation:
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
Prerequisite:
Experience in tax laws
Course Code:
147300
NY Category of CLE Credit:
Areas of Professional Practice
Total Credits:
1.5 CLE
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SPEAKERS' FIRMS:
About Nossaman LLP
Nossaman LLP’s professionals work across offices in Sacramento, San Francisco, Los Angeles, Irvine, and Carlsbad, California; Austin, Texas; Washington, DC; and Seattle, Washington. Our national and multi-disciplinary approach combines the skills and experience of our transactional and regulatory attorneys, litigators, and state and federal policy advisors to achieve clients' goals.
Nossaman’s practice focuses on corporate, employment, healthcare, intellectual property, real estate, environment and land use, infrastructure, public policy, eminent domain and valuation, public pensions and investments, water law, and insurance recovery.
Our tax practice spans these practice areas and covers international, federal, state, and local taxation. We advise and represent individuals, real estate professionals, start-up and, established companies, public entities, and other clients in forming, building, operating, and combining businesses; audits and tax controversies; forming and operating tax-exempt entities; real estate and other investments; and tax planning.
Website: https://nossaman.com/
About Seyfarth Shaw LLP
Seyfarth Shaw LLP provides legal counsel to client companies and legal teams of all sizes. With more than 850 attorneys in the U.S., London, Shanghai, Hong Kong, Melbourne and Sydney, Seyfarth offers a national and international platform to serve business and legal needs in litigation, employment, corporate, real estate and employee benefits.
Website: https://www.seyfarth.com/
About Farrell Fritz, P.C.
Farrell Fritz has built its reputation on trust, open communication and results. Since our founding in 1976, our mission has remained steadfast – to bring success to our clients, service to our community and honor to our profession.
Recognized as one of the most respected, progressive and dynamic law firms on Long Island, Farrell Fritz is home to more than 85 attorneys offering strong experience and depth in a diverse range of practice areas.
Our attorneys counsel corporations and individuals throughout the metropolitan New York region and beyond. Our partners are recognized leaders in their fields and are highly knowledgeable in the industries they serve.
When asked to define what separates us from other law firms, time and again our clients cite the core values that form our foundation. Among these are:
The highest level of integrity. Many law firms claim to have it. But few have established as strong a reputation for delivering what they promise as Farrell Fritz.
A team-oriented “no surprises” approach that emphasizes consistent communication.
A commitment to deliver the highest level of services cost-effectively – so that our clients’ success is measurable on their bottom line.
Uncommonly strong depth of talent in each practice area.
A unique understanding of the most complex legal issues.
Website: https://www.farrellfritz.com/