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PLI - Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2016

PLI California Center, 685 Market Street
San Francisco, CA

This three-day seminar has been designed to ensure that all attendees will benefit, from beginners to experts. The conference will teach and illustrate the partnership tax rules from the birth of the partnership, through its operating life, and on to its wind down, with an emphasis on practical planning strategies. Cooley partner Todd Gluth will be speaking on the topic of troubled partnerships.

What You Will Learn & Special Features
• Overview of partnership income taxation's place in the overall U.S. tax system
• The benefits and detriments of choosing the partnership form
• Avoiding the partnership form for certain strategic alliances
• Partnership interest basis issues, including allocation of liabilities
• Determinations of partners' distributive shares and the effect of liabilities
• Drafting partnership agreement allocation and distribution provisions
• Partnership compensatory interests including options and phantom equity, with a government panelist
• Planning under Section 704(c)
• Formation of partnerships, including joint ventures of operating businesses
• "Topside" planning for private equity investments
• Transactions between the partnership and partners, including exit strategies
• Dispositions of partnership interests, partnership distributions and terminations
• Hedge fund structures and tax planning for managers and investors
• Publicly traded partnerships and the rules of Section 7704
• Economic substance, judicial doctrines and ethics issues
• Interesting partnership transactions of the past year
• IRS and Treasury representatives discussing the government perspective on key partnership issues
• International joint venture issues and planning, including a government panelist
• Effects of recent or proposed tax legislation and pending regulatory proposals

Event information and registration


Related Contacts
Todd Gluth Partner, San Diego
Related Practices & Industries