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Connecticut Bar Association: Applying the IRS Safe Harbor Rules to the Tax Allocation Provisions of Operating Agreements

March 13, 2012
6:00 PM EST

Speakers: Louis B. Schatz

When:
March 13, 2012
6:00 PM EST
Where:
Quinnipiack Club
221 Church Street
New Haven, CT

The Connecticut Bar Association Business Law Section will host a panel on, "Unraveling the Mysteries of Tax Allocation Provisions." The panel will explain the fundamentals of the tax allocation provisions for pass-through entities and review alternative approaches for achieving specific economic results. After providing a general overview of the safe harbor allocation provisions under the Section 704(b) regulations, the panel will delve into the mysteries of the qualified income offset (QIO), the gross income allocation (GIA), and the partners interest in the partnership (PIP) approaches. The panel will compare the advantages and disadvantages of the tax-driven and distribution driven approaches and also consider the benefits of the different methods for dealing with built in gain under section 704(c). The program will focus on several common economic scenarios, including a common/preferred unit structure and profits interest provisions. Sample tax provisions for operating agreements will be distributed at the meeting.

Panelists:
Louis B. Schatz, Partner at Shipman & Goodwin LLP

Brian Newman, CPA, Partner at J.H. Cohn

Leslie E. Grodd, Partner at Halloran & Sage LLP

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