[Webinar] Note Modifications; Reorganization of private companies; Commercial Interest Sale Trust – October 26, 4:00 PM – 5:30 PM CDT | Thompson Coburn LLP

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October 26, 2021

4:00 p.m. – 5:30 p.m. CDT

Taken from Steve Gorin’s Q3 2021 newsletter, this course explains whether a grade change is an exchange, which can be especially important for planning an irrevocable grantor trust if the tax bill from the house to finance the infrastructure is adopted; certain joint reorganizations of private companies and IRS practice units dealing with partnership tax matters; and planning an irrevocable trust selling a flow-through entity to avoid tax traps and take advantage of opportunities.

We will discuss changes to the Notes that constitute an exchange, payment plans in kind rather than cash, and strategic issues related to attempting to discount tickets. We will analyze how these inform planning if the council tax bill is enacted, but this knowledge is important whether enacted or not.

Then we will move on to the reorganization of private companies. While a proposal would allow some pre-1997 S corporations to convert partnership income tax tax-free, we will discuss how to migrate future increases in value and possibly most. from present value to taxation of partnerships even without this change. It will also include a 2021 letter decision on how to isolate risky elements of a business from less risky components. We will briefly review the IRS Practice Units released in 2020-2021 regarding selected partnership issues and where to find them in Steve’s papers.

Finally, we’ll discuss planning to avoid tax traps and take advantage of opportunities when a trust sells stock in an S corporation, including when to turn off the grantor’s trust powers, watching for discrepancies between expectations when of the sale and what appears on each owner’s K-1. , and not only anticipatory planning but also retroactive QST planning. We will also discuss how this differs from planning to sell a partnership interest.

KEY
California: 1.5 overall
Illinois: 1.5 overall
Missouri: 1.8 overall
New York: (1.5 general – experienced; 1.5 general – transition)
Texas: 1.5 general (pending)

Loudspeakers

Steve Gorin
Partner
Thompson Coburn LLP

Steve is a nationally recognized practitioner in the areas of estate planning and private business structuring. Lawyers, accountants and business owners regularly turn to Steve for new and very knowledgeable information on the best possible tax and estate planning approaches for their transactions.


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