How you will benefit:

● Understand the tax implications of entity classification elections under

the US 'check-the-box' rules

● Evaluate the cost benefit of operating a partnership or hybrid entity structure

● Understand the interplay amongst partnership contribution, distribution and

liquidation rules

● Understand compliance requirements and penalties involved in a US-controlled

foreign partnership or hybrid entity structure

Agenda

Day 1

● The legal framework of partnership law

● Classification of entities for federal income tax purposes

● Review and discussion of contributions to and distributions from partnerships

● Tax treatment of partners and partnership income

Day 2

● Overview of US disclosure rules impacting partnerships and hybrid entities

● Partnership distributions, guaranteed payments and distributions

● Discussion of issues stemming from the sale of partnership interests

● International aspects of taxation of partners and partnership income

Level: Intermediate