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Partnership Taxation: Allocations in Partnership and LLC Agreements

 

Understand the rules governing partnership allocations and the commercial import of choices and elections that can be made.

Partnerships and limited liability companies are among the most common business entity types in the United States. They are prized for their 'flow-through' tax benefits for both large and small businesses. However, the tax rules governing the allocation of partnership income and loss are among the most technical, complex, and commonly misunderstood in the Internal Revenue Code, resulting in unintended tax consequences. This presentation will help tax and business professionals better understand the rules governing partnership allocations and the commercial import of choices and elections that can be made within those rules.

Agenda

Faculty

Michael P. Spiro

Michael P. Spiro

Finn Dixon & Herling LLP

  • Partner and Tax Group Chair, Finn Dixon & Herling LLP
  • Practice emphasizes tax planning for domestic and international transactions including, mergers and acquisitions, growth equity investments, leveraged finance, and private equity and hedge fund formation
  • Frequent speaker for the New York State Society of CPAs, Foundation Research Associates Hedge, and Private Equity Fund Tax Seminars
  • Frequently published author
  • Member of the Connecticut Bar Association Tax Section Executive Committee, American Bar Association
  • J.D. degree, University of Pennsylvania; LL.M. degree in taxation, Temple University; B.A. degree, Brandeis University
  • Can be contacted at [email protected] or 203-325-5067

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