US taxation of partnerships and hybrid entities

How you will benefit:

• Understand the tax implications of entity classification elections under the US 'check-the-box' rules
• Evaluate the cost benefit of operating a partnership or hybrid entity structure
• Understand the interplay amongst partnership contribution, distribution and liquidation rules
• Understand compliance requirements and penalties involved in a US-controlled foreign partnership or hybrid entity structure

Agenda

Day 1

• The legal framework of partnership law
• Classification of entities for federal income tax purposes
• Review and discussion of contributions t o and distributions from partnerships
• Tax treatment of partners and partnership income

Day 2

• Overview of US disclosure rules impacting partnerships and hybrid entities
• Partnership distributions, guaranteed payments and distributions
• Discussion of issues stemming from the sale of partnership interests
• International aspects of taxation of partners and partnership income

Level:   Intermediate

Book online or alternatively, book by phone on +44 (0)20 7847 5804

EATI Members: £998.75 €1,250.00

If you register 30 days before event: £948.81 €1,187.50

If you register 60 days before event: £898.88 €1,125.00

Non Members: £1,222.00 €1,500.00

If you register 30 days before event: £1,160.90 €1,425.00

If you register 60 days before event: £1,099.80 €1,350.00

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