Handbook for Mastering Basis, Distributions, and Loss Limitation Issues for S Corporations, LLCs, an

• Determine initial basis and organizing tax-free under §351 and §721
• Understand what affects basis and how to treat distributions
• Pass the four loss limitation hurdles to deduct pass-through losses

• Applicable coverage of tax reform
• Discuss a proposal for a yet to be developed new tax form, which calculates basis, designed to be attached to individual returns
• Executor’s new IRS form for disclosing basis in certain distributed property; what about the basis of a property distribution from a trust?
• How §179 limitations affect basis and how tax-benefit rule is applied
• Basis implications of personal assets converted to business use
• How to calculate basis of inherited qualified and joint tenancy property
• S corporations: Beware of final IRS regulations regarding “open debt”; determine how to calculate basis; worksheets are included; understand the effect of stock basis and debt basis and IRS’s recent focus on "at-risk basis" for shareholders; recognize how AAA applies or doesn’t apply to S corporations; learn to apply the complex basis ordering rules and special elections that can have a big tax result; discuss loss limitation rules in depth; when you can have a taxable dividend in an S corporation; understand distributions of cash and property; understand the post-termination transition rules, which will be important if (when) tax changes bring the return of C corps
• LLCs and partnerships: Learn the detailed rules of §704 for preventing the shifting of tax consequences among partners or members; learn to calculate basis under §704 & for “at-risk” under §465; recognize how recourse, nonrecourse, and qualified nonrecourse debt can create significantly different tax results; learn the difference between basis and “at-risk basis”; review §754 step-up in basis rules; the economic effect equivalence test or “dumb-but-lucky” rule; learn to apply the complex rules of distribution of cash vs. property