Monday, April 8, 2019

Loss Utilization Planning After the 2017 Tax Act

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Loss Utilization Planning After the 2017 Tax Act
April
 
22
1 pm - 2:30 pm ET
Presenters: James Brockway, Louis Piscatelli, and Ryan LoRusso, of Withers Bergman LLP
Credits: CPE, IRS EA, CLE in all states (Credit Details)
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Course Description
 
In this practical webinar, you will learn how the 2017 Tax Act has changed the rules with respect to planning for the use of various tax losses as offsets to current and future taxable income. Upon course completion, you will be able to:
  • Identify the changes to the utilization rules for net operating losses and determine when in certain circumstances acceleration of deductions may not be advisable
  • Describe how to segregate net operating loss pools for purposes of understanding how they will be absorbed in 2018 and future years
  • Identify circumstances and taxpayer types when the rules for excess business losses as to non-corporate taxpayer will be applicable
  • Describe the integration between passive losses and net operating losses
  • Outline instances where the presence of net operating losses can affect the deduction for:
    • Qualified business income (QBI)
    • Global intangible low-tax income (GILTI)
    • Foreign derived intangible income (FDII)
  • Determine how the loss utilization rules affect business valuation and tax sharing agreements
  • Identify implications relating to the intersection of the interest deduction limitation rules of Section 163(i) with net operating losses
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About The Presenters
 
James Brockway is a partner in the private client and tax team at Withers Bergman LLP. His practice is global in scope with particular emphasis on offshore trust planning, planning for non-US individuals and foreign assets, family investment and business planning, family offices, inbound and outbound business transactions and income, and transfer tax planning. Mr. Brockway advises on corporate and partnership tax planning for closely held businesses, investment entities and funds management entities, mergers and acquisitions, and insurance and derivatives investment tax planning.
The Presenter
Lou Piscatelli is a partner in the private client and tax team at Withers Bergman LLP, with a focus on estate administration and probate. His practice includes tax, trust, and estate planning for domestic families, with particular emphasis on planning for closely held businesses. His work for clients involves a range of matters, from creating wealth and business succession structures to general legal business advice.
The Presenter
The Presenter
 
Ryan LoRusso is an associate in the private client and tax team at Withers Bergman LLP. His practice focuses on domestic and international income tax planning for individuals and closely held businesses. Mr. LoRusso advises on partnership and corporate structures, and reorganizations, mergers, and acquisitions.
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