Partnerships - LLC
88 episodes - English - Latest episode: over 3 years ago - ★★★★★ - 1 ratingCovers recent cases, rulings, regulations, and legisation dealing with partnerships, LLCs, and similar pass-through entities.
Homepage Apple Podcasts Google Podcasts Overcast Castro Pocket Casts RSS feed
Episodes
Bob Keebler, Mary O'Reilly, and Stephen Breitstone on the Grantor Retained Interest Partnership
December 03, 2020 22:40 - 17.6 MBIn this 23-minute podcast, Bob Keebler, Mary O'Reilly, and Stephen Breitstone discuss the use of a GRIP - a Grantor Retained Interest Partnership - to use the estate and gift tax exemption in 2020 while retaining access to assets. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Video Podcast: Keebler and Shenkman on the PPP Flexibility Act
June 05, 2020 00:27In this 12-minute video podcast, Bob Keebler and Marty Shenkman discuss the Paycheck Protection Program Flexibility Act, passed by both houses of Congress and expected to be signed by the President. Recorded June 4, 2020. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler on Notice 2019-07
January 25, 2019 01:02 - 8.87 MBWhen does the rental of real estate constitute a trade or business for purposes of Code section 199A? Bob Keebler analyzes Notice 2019-07 in this 10-minute podcast. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler: An Overview of Section 199A Final Regulations
January 25, 2019 00:58 - 17.4 MBIn this 19-minute podcast, Bob Keebler provides an overview of the final section 199A regulations and Notice 2019-07. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler on Tax Planning Under the Section 199A Regulations
August 20, 2018 04:14 - 14.1 MBIn this 15-minute podcast, Bob Keebler discusses planning strategies under the Section 199A proposed regulations. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler -- Overview of the Section 199A Proposed Regulations
August 17, 2018 04:37 - 12.8 MBIn this 14-minute podcast, Bob Keebler provides an overview of the proposed regulations implementing the income tax deduction for qualified business income. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler on Section 199A: An Executive Summary
August 08, 2018 07:55 - 15.6 MBIn this 17-minute podcast, Bob Keebler explains new Code section 199A and the planning opportunities it presents. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Tax Planning for Real Estate Under TCJA
March 16, 2018 22:05 - 18.4 MBIn this 20-minute podcast, Bob Keebler discusses income tax planning for real estate investors under the Tax Cuts and Jobs Act, including the new Code section 199A deduction. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler on the Newly Passed Tax Bill
December 21, 2017 04:42 - 6.72 MBIn this seven minute podcast, Bob Keebler provides an overview of the tax bill and discusses immediate actions that should be considered by clients. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler, Angkatavanich and Dougherty on Estate of Purdue v. Commissioner
January 11, 2016 00:18 - 19.5 MBIn Estate of Barbara M. Purdue et al. v. Commissioner, T.C. Memo. 2015-249 (December 28, 2015), Tax Court Judge Goeke ruled favorably on the estate and gift tax aspects of a family limited liability company. In this podcast, Bob Keebler discusses the case and its implications for estate planning and administration with N. Todd Angkatavanich and James I. Dougherty. For a written analysis of the Purdue case, see LISI Estate Planning Newsletter #2374 (January 11, 2016). This Podcast is sponso...
Bob Keebler on the NIIT and Real Estate
February 05, 2014 05:28 - 2.88 MBBob Keebler analyzes the application of the 3.8% net investment income tax (NIIT) to activities of real estate investors and professionals. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler and Shenkman: Planning
October 12, 2012 22:42 - 4.63 MBBob Keebler and Marty Shenkman discuss planning between now and December 31st. The time is crucial and the opportunity is not to be missed. Marty has created a postcard to inform clients of 2012 planning opportunities. A company called "Printing for Less" - which does Marty's newsletter - will customize and mail it for any practitioner at a 20% discount off printing costs + postage. (Marty gets no payment from this). You can use his postcard primarily with no royalties (but a nice not...
Keebler - Covered Opinion Rules
September 18, 2012 06:51 - 1.47 MBBob interviews attorney Michael Goller who discusses the new Covered Opinion Proposed Regulations. This is a very important development focusing on Section 10.37 - dealing with tax opinions and how attorneys must comply. Also stressed in this interview is section 10.35, which requires competence and 10.36 dealing with management oversight proceedures and standards. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our soft...
Keebler and Blattmachr - Planning in 2012
January 31, 2012 02:12 - 3.63 MBStars Bob Keebler and Jonathan Blattmachr discuss multiple planning tactics and considerations for this most important and pivotal year. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler and Oshins - Recent Democratic Estate Tax Proposals
September 19, 2011 05:58 - 3.05 MBBob Keebler discusses with Las Vegas attorney Steve Oshins recent proposals by the Obama administration that would impact significantly on estate tax laws and planning. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Paul Hood - Valuation Discounts for Lack of Marketability
September 08, 2011 05:54 - 6.41 MBValuation authority, Paul Hood, discusses discounts for lack of marketability. Paul will be presenting, in conjunction with Phil Cavesh, a program called A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques. For information or to sign up: http://www.ultimateestateplanner.com/092811PH.html This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations ...
Bob Keebler and the Section 1022/AMT Election 'Curveball'
August 29, 2011 21:26 - 1.8 MBIn this important PodCast, Bob Keebler reviews what he is calling the Section 1022 Election/AMT 'Curveball.' According to Bob, it appears that there is a strong possibility that taxpayers electing carryover basis will have different basis for AMT and regular tax purposes. This, according to Bob, appears to have been missed by the tax writing committees and the IRS. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our softwar...
Tax Planning Opportunities in Volatile Economic Environments
August 22, 2011 03:37 - 3.51 MBIn this PodCast, Bob Keebler reviews a variety of strategies that can immediately help clients with their stock and bond investments. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses Revenue Procedure 2011-41
August 10, 2011 06:55 - 1.8 MBBob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler focuses on Notice 2011-66
August 10, 2011 06:52 - 1.8 MBIn this PodCast, Bob Keebler focuses on Notice 2011-66, the 1022 election not to pay estate tax, along with impact of Form 8939 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Budget Control Act of 2011 Part 2 of 2
August 10, 2011 06:44 - 1.8 MBIn this PodCast, Bob Keebler focuses on the tax issues raised by the Budget Control Act of 2011, along with what Congress might do in in the future. Bob also reviews the things advisors should be doing to help their clients. This is Part 2 of 2 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Budget Control Act of 2011. This is Part 1 of 2
August 10, 2011 06:30 - 2.36 MBIn this PodCast, Bob Keebler reviewd the current fiscal situation and important dates contained in the Budget Control Act of 2011. This is Part 1 of 2 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler - Carried Interest
June 07, 2010 00:16 - 5.4 MBBob Keebler talks about the issue of "carried interest" and the Bill working its way through the House and Senate. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
WILMINGTON TRUST - FUTURE VISION OF ESTATE PLANNING - PART IIA
May 11, 2010 01:15 - 24.2 MBThis is Part IIA of Wilmington Trust's "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick Nenno and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Be sure to listen to Part III. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Pleas...
Wilmington Trust - Future Vision of Estate Planning - Part III
May 07, 2010 23:55 - 18.2 MBThis is Part III of Wilmington Trust's "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick Nenno and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Our thanks to Dick Nenno, Carol Cantrell, Read Moore, and Jeff Pennell for a terrific view of where we are now and what's coming up. This Po...
Wilmington Trust - Future Vision of Estate Planning - 2010 - Part II B
May 07, 2010 06:10 - 9.36 MBThis is Part II of Wilmington Trust's "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick Nenno and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Be sure to listen to Part III. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please...
Wilmington Trust - Future Vision of Estate Planning - Part 1
May 06, 2010 07:00 - 26.3 MBDick Nenno of Wilmingtion Trust returns to provide a "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Be sure to listen to Parts II and III. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservic...
Net Operating Loss Guidance: Let's Try This One Again - Ed Zollars
May 03, 2009 05:29 - 9.69 MBThis PodCast is about Net Operating Losses. The IRS has issued a revised ruling on the use of a net operating loss under the new rules Congress added in February. The new ruling, Revenue Ruling 2009-26, updates and liberalizes the guidance previously given in Revenue Ruling 2009-19 issued on March 16. The new guidance allows taxpayers to simply file a carryback for the appropriate number of years to make the election, but there are special due date rules you have to worry about. T...
It's a Matter of Trust Funds - the Responsible Person Penalty - Ed Zollars
February 22, 2009 00:03 - 38.2 MBThis PodCast concerns a case dealing with the trust fund recovery penalty under "6672. In the case of Richard A. Smith v. United States, 2009 TNT 30-6, CA10, (http://ca10.washburnlaw.edu/cases/2009/02/07-4210.pdf) the Tenth Circuit refused to overturn the holding in the US District Court of Utah that Mr. Smith was a responsible person, even though he had no ownership interest in the entity in question. The case highlights the dangers for employees in accounting functions when the org...
Losses and Choices-Stimulus Bill Net Operating Loss Rules - Ed Zollars
February 16, 2009 04:58 - 24.7 MBThis PodCast is about the American Recovery Reinvestment Act of 2009. It has a number of tax provisions, and this podcast looks at the small business net operating loss provisions of the Act. This provision will require action for some taxpayers within 60 days after the bill is signed into law, as well as giving us a "sliding" window for when we start using a net operating loss for the year we elect to have it apply to. The podcast materials are located at http://www.edzollars.com/2009-02...
Delayed Rebate-Tax Status of Accrued Rebates - Ed Zollars
August 31, 2008 01:43 - 11.4 MBThis PodCast pertains to a common accounting issue, the differences between tax and GAAP treatment of items. Here, we focus on a case involving the time for recognizing an expense. The matter involved rebates and we look at a Chief Counsel Memorandum (ILM 200834019) outlining the IRS's view on why the taxpayer in this case could not recognize the expense related to rebates at the time a sale was made. Materials for this week's podcast can be downloaded at http://www.edzollars.com/2008-09...
I Wish That Hadn't Worked--Section 83(b) Election Regret - Ed Zollars
August 03, 2008 05:21 - 13 MBThis podcast is the sequel to a November 2006 podcast on the same case--that of Kadillak v. Commissioner where an individual who was caught by the "dot bomb" crash of the technology stock of his former employer attempted to mitigate the damage caused by his ISO exercise and 83(b) election made at the height of the craze. A year later, Mr. Kadillak was no longer employed by the organization, the stock price had tanked, and when he sold the stock that he didn't have to surrender got stuck wit...
Heeding Warnings-Taxpayer Penalized After Preparer Shopping - Ed Zollars
July 27, 2008 04:32 - 12.9 MBThis PodCast is about the preparer standards and tax return positions. In the case of Wadsworth v. Commissioner, TC Memo 2008-171, we see a real world situation where a tax professional decided a position was not one that he could accept and what happened when the client decided to find another person who would take the requested position. As you might expect, the taxpayers don't fare well in the eyes of the court when they attempt to claim reliance on the advice of the professional that d...
Getting Started Automatically - IRS Modifies Rules for Start Up and Organization Costs - Ed Zollars
July 13, 2008 02:20 - 16.7 MBThis Podcast is about temporary regulations that deal with start-up and corporate and partnership organization costs. Interestingly enough, the new regulations now create an automatic election to expense/amortize all such costs, and treat problems related to the identification of costs or the proper year to begin amortization as accounting method issues. The materials are located online at http://www.edzollars.com/2008-07-14_Section_195.pdf . This Podcast is sponsored by Leimberg Informat...
IRS Releases New FAQ on HSAs - Ed Zollars
June 29, 2008 05:58 - 25.8 MBThis Podcast pertains to HSA Accounts. The IRS has issued guidance in the form of a series of questions and answers related to Health Savings Account in Notice 2008-59. This podcast covers some of the planning and design opportunities available under this Notice. Written materials for this podcast can be downloaded from http://www.edzollars.com/2008-06-30_HSA_Guidance.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit...
Proposed Regulations for Preparer Penalties - Part Two - Ed Zollars
June 26, 2008 04:37 - 25.6 MBThis PodCast is part two of a series on the proposed regulations for preparer penalties. . The materials are at http://edzollars.com/2008-06-23_Penalty.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Proposed Regulations for Preparer Penalties - Part One - Ed Zollars
June 22, 2008 06:05 - 29.3 MBThis PodCast is the first of what will be a series of two on the proposed regulations for preparer penalties. Considering the length of the regulations and podcast, the first hour is in this file to listen to and digest, with part two to be posted later. The materials are at http://edzollars.com/2008-06-23_Penalty.pdf . . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations sit...
Step or No Step - Holman Case - Ed Zollars
June 08, 2008 05:13 - 13 MBThis PodCast reviews the step transaction doctrine and where the line is drawn when we deal with the application of the step transaction doctrine in the formation of a family limited partnership. The IRS attempted to use their victory in the Senda case to get the same result in Holman v. Commissioner, 130 TC No. 12. But in an opinion that reminds us of the importance of the facts of the specific case in question, the Tax Court refused to take that step. Materials for this week's podcast c...
Partnership Liabilities, Tax Shelters and Different Views of the Same - Ed Zollars
May 17, 2008 05:52 - 18.1 MBThis PodCast deals with a Fifth Circuit ruling in Kornman & Associates, Inc. v. United States on whether a taxpayer who set up a Son of BOSS style shelter would get the benefit that was expected--and the taxpayer was disappointed. The case offers a chance to review the unusual impact that liabilities have in a partnership context, as well as the question of just what is a liability for this purpose. The materials for this podcast can be downloaded at http://www.edzollars.com/2008-05-19_Par...
Sloppiness and the Tax Shelter - Ed Zollars
May 04, 2008 00:54 - 13.2 MBThis PodCast is about the interplay between partnership taxation and tax shelters taken beyond the spirit of the law. Partnership taxation is one of those areas where things may not work exactly as many practitioners expect, and those unexpected workings are things that tax shelter promoters have attempted to make use of. But if you are going to try and use the technical details of the tax law to force the IRS to grant you a tax benefit that otherwise doesn't seem like something that should...
Qualified Joint Venture and Memo on Self-Employment Tax - Ed Zollars
April 28, 2008 04:25 - 12.2 MBThis PodCast follows the continuing saga of the self-employment tax and qualified joint venture. It analyzes CCA 200816030 issued by the IRS that outlines the "new improved" IRS position on self-employment tax and the Qualified Joint Venture election under "761(f). The materials for the podcast are available at http://www.edzollars.com/2008-04-28_SEandQJV.pdf . . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our softwar...
The Mailbox Rule Comes Up Once Again - Ed Zollars
April 20, 2008 03:26 - 12.6 MBThis PodCast concerns the issue of whether "7502(c) provides the exclusive means to prove timely filing of a document by a taxpayer. What the Third Circuit had to say, the IRS didn't like hearing. In the case of Philadelphia Marine Trade Ass'n.-Int'l Longshoremen's Association Pension Fund et al. v. Commissioner, 2008 TNT 74-16 the Third Circuit held that the reports of the death of the common law mailbox rule were, in the words of Mark Twain, greatly exaggerated. That places the Third Cir...
Upon Further Review-Self-Employment Tax Issues - Ed Zollars
March 22, 2008 02:48 - 20.5 MBThis PodCast pertains to Self-Employment tax issues. We look specifically at the case authorities we have (which are scant, and not terribly promising for LLC members), the IRS's proposed regulations that were controversial when issued, and what options exist for dealing with the issue today. We revisit an issue raised in a February podcast, as the IRS unofficially "clarifies" their position on the self-employment tax treatment of Qualified Joint Ventures that is presented in the Form 106...
CPA Says Error, IRS Says Accounting Method - Ed Zollars
March 16, 2008 05:58 - 10.6 MBThis PodCast is about the difference between an error and an accounting method. The question of whether a problem on a return was an error or a method of accounting is important. We'll look at the Sixth Circuit's ruling in the case of Huffman v. Commissioner, where the appeals court sustained the 20006 ruling of the Tax Court (126 TC 322) that the CPA's consistent flawed attempt to calculate inventory as prescribed by the regulations for the dollar-value, link-chain LIFO method. The reso...
Risky Business - LLC Debt Restoration Provision Fails to Provide At Risk Status - Ed Zollars
March 09, 2008 05:12 - 10.2 MBThis PodCast examines an LLC debt restoration provision. We look at the Tax Court's second pass at the case of Hubert v. Commissioner, TC Memo 2008-46, a case sent back to the Tax Court by the Sixth Circuit Court of Appeals to decide if the LLC debt restoration provision made the taxpayer the payer of last resort under the Sixth Circuit's test. The Tax Court comes back saying "No". The materials can be found at http://www.edzollars.com/2008-03-10_Risky_Business.pdf . This Podcast is spon...
Not Quite Good Enough-Timely Filing One More Time - Ed Zollars
February 24, 2008 04:26 - 10.4 MBThis PodCast pertains to the issue of "timely filing", revisiting an issue last covered in a podcast back in October of 2005. This time we look at the Tenth Circuit's opinion in the case of Gibson v. Commissioner, a case that illustrates how a taxpayer who thought he was complying with the requirements to prove a timely filing of his Tax Court petition managed to find a way to not get the benefit he thought he had. The materials are available at http://www.edzollars.com/2008-02-25_Timely_F...
Transforming Rental Income to Self-Employment Income - Qualified Joint Ventures - Ed Zollars
February 17, 2008 03:56 - 15.7 MBThis Podcast discusses an issue highlighted in the instructions to Form 1065 and pertains to the side effect that occurs when married taxpayers holding rental property in an LLC or other form eligible to elect Qualified Joint Venture Treatment under "761(f) elect to be treated as a Qualified Joint Venture. The effect is that the rental income (or loss) is no longer exempted from being treated as self-employment income, but now is treated as such. We'll discuss why this is the case, as we...
Economic Stimulus Package of 2008 (Tax Matters) - Ed Zollars
February 09, 2008 04:48 - 13 MBThis PodCast is about the Economic Stimulus Package of 2008. It makes a few, but significant, tax law changes for 2008. This podcast talks about what Congress did and what we need to do about it. Materials are available at http://www.edzollars.com/2008-02-09_Economic_Stimulus.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
So You Want Your LLC to Be An S Corporation - Ed Zollars
February 05, 2008 02:55 - 21.2 MBThis PodCast focuses on issues involved with LLCs and S corporations. This topic cuts across what is often covered in partnership discussions (the use of LLCs) and S corporations (where often LLCs are presented as an alternative to, rather than a potential form of, an S corporation). The podcast covers issues that arise when a single member LLC is used to hold S corporation stock, as well as when an LLC elects corporate status and wishes to be taxed under the S corporation rules. The mater...
Consenting to Disclosure or Use of Return Information - Ed Zollars
January 21, 2008 02:05 - 20.4 MBThis PodCast concerns Revenue Procedure 2008-12 and final regulations under "7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers. The regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms. These new requirements will take effect on January 1, 2009. The writt...