Partnerships
Hosted By Baker McKenzie and Ernst & Young
Thursday, April 19, 2018
Baker McKenzie office
300 E Randolph, 50th floor
Please join TEI’s Chicago Chapter for a full day program presented by Baker McKenzie and Ernst & Young focused on partnerships, as geared for the corporate tax practitioner, including a concentration on the recent tax reform changes and new provisions. Agenda
Date/Time
Workshop
Leaders
Details
8:00 - 8:50 am
Breakfast
8:50 - 9:00 am
Introduction
S. Schneider (BM)
T. Golub (EY)
9:00 - 10:00 am
Partnership Overview & Drafting and Reviewing Partnership Agreements (LPAs, JVs, LLCs)
Morgan Anderson (EY)
L. Gruen (BM)
S. Grilli (BM)
Overview of the mechanics of a tax partnership including: tax accounting and capital accounts; property contributions and distributions; and “disguised sales”, with a focus on the basic considerations when drafting or implementing a partnership agreement including: election considerations; Partnership “Allocations” including “Targeted Allocations” and the “Tax Matters” section.
10:00 - 10:10 am
Break
10:10 - 11:40 am
(provide 5 minute break)
Overview of Tax Reform Changes to Partnerships & New Planning Considerations after Tax Reform
M. Melrose (BM)
Maximilian Pakaluk (EY)
Removal of technical terminations, the new passthrough rate, carried interest holding periods; interest deduction limitations; UP-C Structure Planning.
11:40 - 12:30 pm
Cross-Border & International Partnerships and JVs: Outbound International Tax Considerations Including Tax Reform Changes
S. Hadjilogiou (BM)
M. Bruno (BM)
C. Munz (EY)
Outbound Tax Related Issues & Planning Ideas in the Partnership / Corporate Context: GILTI; FDII; Aggregate treatment of partnerships for ECI purposes.
12:30 - 1:30 pm
Lunch: “Ask the Experts”
R. Lipton (BM)
Todd Golub (EY)
This lunch panel will allow the audience to ask questions of their choice to the panel of partnership tax specialists.
1:30 - 2:20 pm
SALT
T. Bots (BM)
R. Patzner (BM)
M. Randall (EY)
Discussion on the major state implications of tax reform on partnerships. Additional discussion on entity level taxation, apportionment issues, nonresident withholding and composite tax and audit issue/partnership audit rules.
2:20 - 2:30 pm
2:30 - 3:25 pm
Partnership Audits
M. Haddad (BM)
S. Kamyans (BM)
J. Welbel (BM)
Mechanics of the new Partnership Audit Rules; Drafting and Planning Considerations; Treatment of Current vs. Historical Partners; Classification of Imputed Underpayments; Other Tax Litigation Considerations Involving Partnerships
3:25 - 4:00 pm
Compliance and Reporting
C. Griswold (EY)
4:00 - 5:00 pm
Cocktail Hour
50th Floor
The cost for this meeting is $25 for TEI members and $55 for non-TEI members. Season ticket holders may use their season pass. Questions – please contact Irene Brajner at imbrajner@aol.com. For registration information, please visit: https://www.eventbrite.com/e/tei-chicago-chapter-tax-partnerships-tickets-43335788510 .
CPE and Illinois CLE available. This event is limited to professionals working in private industry.
(+1) 202.638.5601 (+1) 202.638.5607
1200 G Street, N.W. Suite 300 Washington, D.C., 20005 U.S.A.
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