Thursday, October 19
4:00PM - 6:00PM
Partnerships & LLCs Task Force on Simplification of Subchapter K
Friday, October 20
2:30PM – 5:30PM
Partnerships & LLCs
Chair: James E. Wreggelsworth, Davis Wright Tremaine LLP, Seattle, WA
2:30pm Opening Remarks by the Chair.
2:35pm Identifying Partners’ Interests in Partnership Profits and Capital. Numerous Code provisions and regulations determine “relatedness” by reference to the ownership percentages of a partner’s interest in partnership profits and/or in capital. Meeting or not meeting the requisite percentage interest can have profound tax consequences both inside and outside subchapter k. Sophisticated arrangements are particularly subject to measurement uncertainty. This panel will discuss how such interests should be measured in the absence of meaningful guidance and the traps and planning opportunities that exist. Moderator: Sheldon I. Banoff, Katten Muchin Rosenman LLP, Chicago, IL. Panelists: Adam M. Cohen, Holland and Hart LLP, Denver, CO; Steven R. Schneider, Miller & Chevalier Chartered, Washington DC.
3:25pm State Tax Developments Affecting Partnerships & LLCs. This panel will discuss recent changes in state tax laws affecting partnerships and LLCs, including the extension of the Texas Franchise Tax to limited partnerships and the recent developments concerning the constitutionality of the LLC Tax and Fee under California law. Moderator: Carolyn J. Lee, Roberts & Holland LLP, New York, NY. Panelists: Cynthia M. Ohlenforst, Hughes & Luce LLP, Dallas, TX; Michael W. McLoughlin, Morrison & Foerster LLP, New York, NY.
4:15pm Hidden Issues in Partnership Unwinds, Acquisitions and Restructurings - Rev. Rul. 99-6 and Other Traps. B Many partnership and LLC agreements afford the partners liquidity rights, often through buy-sell provisions and purchase options. This panel will discuss tax consequences arising on cross- purchases and restructurings, including the uncertainties to the purchasing and selling partners as a result of the deemed liquidating distributions under Rev. Rul. 99-6 when a partnership or LLC is reclassified as a disregarded entity as a result of the transaction. Moderator: Deborah A. Harrington, Deloitte Tax LLP, Washington, DC. Panelists: Daniel F. Carmody, Morgan Lewis & Bockius LLP, Philadelphia, PA; Beverly M. Katz, Senior Technician Reviewer, Passthroughs & Special Industries, Office of Chief Counsel, IRS, Washington, DC.
5:00pm Hot Topics in Partnership. This panel will discuss recent developments affecting partnerships including legislation, regulations, administrative guidelines and recent noteworthy cases. Moderator: Jeanne M. Sullivan, KPMG LLP, Washington, DC. Panelists: Beverly M. Katz, Senior Technician Reviewer, Passthroughs & Special Industries, Office of Chief Counsel, IRS, Washington, DC.
