Register for the Advanced Tax Strategy Series with Matthew Foreman

Join Matthew E. Foreman, Esq., LL.M., Co-Chair of FRB’s Taxation Practice Group, for the Advanced Tax Strategy Series, a four-part webinar program designed for professionals seeking deeper insights into sophisticated tax planning.

New York CLE and CPE, CFP CE, and IRS CE credits are available for all sessions (1.0 credit per session). Learn more and register below: 

Thursday, November 6 | 1:00pm - 2:00pm ET

704(c) Allocations: Traditional, Curative, Remedial, and Other “Reasonable” Methods

• Explore one of the most complex and misunderstood areas of partnership taxation, allocation methods under I.R.C. § 704(c). He will discuss the three methods that are allowed under Treas. Reg. § 1.704-1: Traditional, Traditional with Curative Allocations, and Remedial; the Ceiling Rule problem and how each method creates or mitigates the Ceiling Rule problem; and whether Other Reasonable Methods are really a viable option.

Thursday, November 20 | 1:00pm - 2:00pm ET

Succession Planning at the Margins: Using Profits Interests in Estate Planning

• Discuss various estate planning techniques relating to the use of profits interests under Rev. Proc. 93-27. He will discuss the use of various tax-free reorganizations under I.R.C. § 368 to facilitate the use of profits interests, as well as what profits interests should (and should not) be used to accomplish, especially in the estate planning context. There will be a specific focus on I.R.C. § 83 and when to make an 83(b) election.

Thursday, December 4 | 1:00pm - 2:00pm ET

Stock Sales Taxed as Asset Sales: Pre-Sale F Reorganizations; Selling Wholly-Owned Subsidiaries; and Elections under 336(g), 338(h)(10), and 336(e)

• Examine tax-free single-business reorganizations under I.R.C. § 368, how they’re used when selling businesses, and possible pitfalls. Further, he will discuss the three elections available to the sellers of C Corporations and S Corporations that allow for the sales of stock to be taxed as if they were the sales of assets, focusing on the mechanics, the benefits and detriments, and the varying tax consequences of each. He will finish with a discussion of how earnouts and other deferred payments are taxed.

Thursday, December 18 | 1:00pm - 2:00pm ET

Qualified Small Business Stock Under Section 1202 of the IRC: Common Mistakes and Misconceptions

• Explore the recently-amended I.R.C. § 1202, the exclusion for gain from certain small business stock. HE will give an overview of how to qualify and how it works, then he will focus on common mistakes made by taxpayers, advisors, and practitioners who are not familiar with one of the quirkiest sections of the Code. He will discuss issues with partnerships and grantor trusts, why living in certain states is disfavored, and why the holding period is often less of a problem than most people anticipate.

For questions or assistance with registering, please fill out the contact form or visit us here. 

DISCLAIMER: This summary is not legal advice and does not create any attorney-client relationship. This summary does not provide a definitive legal opinion for any factual situation. Before the firm can provide legal advice or opinion to any person or entity, the specific facts at issue must be reviewed by the firm. Before an attorney-client relationship is formed, the firm must have a signed engagement letter with a client setting forth the Firm’s scope and terms of representation. The information contained herein is based upon the law at the time of publication.