Total Credits: 8 including 8 Taxes - Technical
The taxation of LLCs and other entities taxed as partnerships continue to change. The IRS is taking an increasingly aggressive approach on application of the self-employment tax to partners and is winning in the courts. There are new, complex audit rules which are now in effect and most clients have not yet changed their agreements to address them. The new 199A pass-through entity deduction continues to evolve as new final regulations were issued in January of 2019. More are on the way!
20 Clients still have issues in connection with the granting of interests to employees and the reporting changes that necessitates as former employees become partners. And the taxation of gain on sale of carried interests has been modified. Some client may want to convert to an S corporation but there are numerous ways to accomplish that, each with slightly different tax consequences.
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C. Clinton Davis, JR. practices law in the Dallas, Texas law firm of Krage & Janvey, L.L.P. He was licensed in Texas in 1982, has been Board Certified in Tax Law by the Texas Board of Legal Specialization since 1988 and is a member of the College of the State Bar of Texas. He has also been licensed as a Certified Public Accountant in Texas since 1980 and as an attorney in Florida since 1980. Mr. Davis attended law school at Southern Methodist University and received his Juris Doctor degree, cum laude, in 1980. At SMU, Mr. Davis was selected to membership in the Order of the Coif, an honor society limited to graduates in the top 10% of the graduating class. Mr. Davis received his bachelor of science degree in accounting from Northwestern State University of Louisiana where he graduated first in his class. Mr. Davis is a frequent speaker at CPE programs and conferences. He is the author of the TSCPA programs Principles of LLC and Partnership Taxation: An Introduction to Subchapter K, Navigating the LLC and Partnership Allocation and Basis Minefield, and LLC and Partnership Taxation for the Sophisticated Practitioner.
Matthew S. Beard, JD, practices with the firm of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., based in Dallas, Texas. His practice spans two broad areas of taxation: estate planning and probate and income tax and business planning. In his estate planning and probate practice, Mr. Beard designs and implements estate and business succession plans with an emphasis on federal tax issues. He often works closely with accountants, bankers and financial advisors in this process. Mr. Beard also represents fiduciaries in all facets of estate and trust administration. This typically includes court proceedings, tax matters, administration and transfer of assets, and matters before the IRS. Mr. Beard is the author of "An Introductory Guide to Tax and Estate Planning," which provides an introduction to estate planning under Texas law and planning for federal estate, gift, and generation-skipping transfer taxes. On transactional matters, Mr. Beard advises clients with a focus on tax issues. He works with a broad range of entities, such as partnerships, limited liability companies, and publicly traded "C" corporations. Transactions include formations, acquisitions/mergers, and liquidations. Mr. Beard is the author of "Annotated Tax Provisions for Limited Liability Companies," which includes tax provisions for company agreements with explanations of how the provisions operate and provide pass-through taxation. Prior to joining the firm in 2012, he was an associate with one of the largest Texas-based law firms.
Bill Wilson, CPA, is a manager in the Passthrough Entities Practice Area in the Internal Revenue Service’s Large Business and International Division. He holds a B.S. in Business Administration with a major in accounting from George Mason University in Fairfax, Virginia, and a Master of Taxation degree from Virginia Commonwealth University in Richmond, Virginia. In addition to his work at the IRS, Bill is an adjunct lecturer in the Graduate School of Management at the University of Texas at Dallas.
Joel N. Crouch, JD, is a partner with the law firm of with Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., based in Dallas, Texas. Mr. Crouch is Board Certified in Tax Law by the Texas Board of Legal Specialization. His practice focuses on resolving or litigating controversies with the Internal Revenue Service. Mr. Crouch represents individuals and businesses in IRS audits, appeals and litigation in United States Tax Court, Federal District Court and Federal Court of Claims. In addition, he has represented clients in resolving tax matters with the State of Texas. In addition to his civil practice, Mr. Crouch also represents individuals and corporations involved in criminal investigations. He has experience in tax fraud, bankruptcy fraud, bank fraud and environmental matters. Mr. Crouch is a member of the Collin County, Dallas and the American Bar Associations, and the State Bar of Texas. He is also a member of the Tax, Criminal and Litigation Sections of each of these organizations. Mr. Crouch is an active speaker on substantive and procedural tax issues for the Texas Society of Certified Public Accountants (TSCPA), TSCPA Chapters and other professional groups. Joel co-authored an article in the May/June 2006 issue of The Value Examiner (National Association of Certified Valuation Analysts publication) titled, "6 Keys to Avoiding Section 6701 Penalties." He was named a Texas Super Lawyer in 2003, 2004 and 2005 by Texas Monthly and Law & Politics Magazine. Mr. Crouch was born in Suffern, New York in 1962. He received his B.A. in Mathematics from Southern Methodist University in 1985 and his J.D. from the University of Texas School of Law in 1988.
Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org
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