Overview
Owners of S corporations and partnerships are subject to various limitations on pass-through losses, each with unique rules, applications, and complexities. As many businesses are reporting losses as a result of COVID-19, it is essential for tax practitioners to understand the mechanical aspects of each limitation and how they coordinate to provide effective planning for loss utilization in future periods.
Prerequisites
Basic familiarity with loss allowance rules of pass-through entities
Objectives
- Understand how the activity of an entity and distributions are handled when basis limitations exist for partnership interest and S corporation stock
- Analyze at-risk amounts for disallowed losses and demonstrate understanding of how the amount and character of suspended amounts are determined
- Understand passive loss limitations and how character and the number of suspended losses are determined
- Analyze excess business loss limitations created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting carryforward amounts
Highlights
- Limitation 1: Basis limitations will be reviewed in detail with computational examples and include insights into similarities and differences between calculations for partnership interests and S corporation stock
- Limitation 2: Detailed at-risk limitation computational examples will be reviewed, and the mechanical features of partnerships and S corporation activities will be compared and contrasted
- Limitation 3: Passive loss limitation mechanics will be outlined in detail and discuss computations where there are a mix of entity structures owned by a taxpayer
- Limitation 4: Excess business losses will be presented from a mechanical perspective
