The new code Section 199A in the 2017 tax act creates a deduction on Qualified Business income for pass-through entities. While the new section may prove beneficial to your clients, 199A is complex. We will walk you through key decision points on determining the best path forward for your clients.
COURSE OBJECTIVES:
Bloomberg Tax
Senior Fellow
[email protected]
(800) 424-2938
Before joining Bloomberg Tax as a tax specialist consultant, Sam Starr served as a tax partner and Chief Tax Officer for PricewaterhouseCoopers LLP (USA). During his years at PwC, Sam served as co-leader of the firm's national tax Pass-Through Entities practice, focusing on partnerships, limited liability companies, and S corporations. He has extensive experience in structuring acquisitions and dispositions for businesses organized as pass-through entities.
Sam is an adjunct professor of law at Georgetown University Law Center, where he teaches taxation of limited liability companies and S corporations.
Sam is the co-author of three current Bloomberg Tax portfolios on S corporations. In addition, Sam co-authors a portfolio on the taxation of limited liability companies. Sam has published articles for various tax journals and has presented at a number of tax conferences.
Bloomberg Tax
Editor
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(800) 424-2938
Ashley Fausset is a Federal Tax Law Editor working in the Business Entities and Tax Accounting Group. She joined Bloomberg BNA in August 2017 after completing her LL.M. in Taxation at Georgetown University Law Center.
Roberts & Holland LLP
Partner
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(212) 903-8700
Elliot Pisem, for more than 25 years, has concentrated on corporate and partnership taxation. Working with a broad range of clients, including real estate investors and developers, he has created, negotiated, and implemented sophisticated partnership arrangements, joint ventures, and corporate structures to accommodate complex transactions. With extensive experience in lessor/lessee issues in real property transactions, tax-free like-kind exchanges, and the structuring and operation of REITs, he has worked with tax-exempt investors; advised on historic rehabilitation projects, charitable contributions of “façade easements” and similar interests in real property; and developed tax-efficient structures for investment by foreign persons in U.S. real property and techniques for acquiring property already held by foreign owners. In addition to taxable and tax-free acquisitions, he has advised on spin-offs and other corporate and partnership divisions, and deals with the taxation of financial instruments, including the application of original issue discount, straddle, and swap rules, and the use of single- and multi-class pass-through certificate structures. He has represented corporate and non-corporate debtors and their creditors in debt restructuring and workout transactions, both within and outside of bankruptcy. He serves on the Executive Committee of the Tax Section of the NY State Bar Association and as Co-Chair of its Committee on Compliance, Practice & Procedure, having previously served as Co-Chair of the Committees on Pass-Through Entities, Partnerships, Tax Accounting Matters, Bankruptcy, Cost Recovery, and Real Property. The committees he has co-chaired have prepared reports on, inter alia, Regulations under Code section 707(a)(2) relating to “disguised sales” of property between partnerships and partners, the transfer pricing Regulations under Code section 482, the “bonus depreciation” Regulations under Code sections 168(k) and 1400(b), and monetary penalties on practitioners under Treasury Department Circular 230. He also co-authors a bi-monthly column on corporate tax matters in the New York Law Journal and writes frequently for the Journal of Taxation and other publications.