Loss Limitation Provisions Applicable to Taxpayers Other Than C Corporations (LLPR)

Michael J. Tucker, CPA, LL.M. (moderator)
  • 3
  • Intermediate
  • Federal Tax Law
On-site : May 15
Webinar : May 15, May 23
Broadcast Times

Individual course: $89
Volume Discounts:Click here for details.

Overview

The Tax Cuts and Jobs Act added Section 461(l) to the Internal Revenue Code, limiting losses previously available. To the extent a taxpayer has an “excess business loss” for the tax year under Section 461(l), that portion of the taxpayer’s overall loss becomes a net operating loss (NOL) carried forward to future tax years and subject to the new rules that govern NOL generated after 2017.  Many owners of S corporations, partnerships and limited liability companies are now subject to four loss limitation provisions. This program covers each loss limitation provision and how they relate to each other.

Major Topics:

  • How the new Section 461(l) loss limitation provisions work
  • The new net operating loss limitation rules and how they relate to Section 461(l)
  • Determination of a taxpayer’s basis in a pass-through entity
  • Suspended losses and deductions due to basis limitations
  • How at-risk rules operate to limit loss deductions
  • Passive activity loss rules that suspend losses

Learning Objectives

  • Understand the four loss limitation rules
  • Advise clients concerning the implementation of the new Section 461(l) loss limitation provision

Tax practitioners who anticipate advising clients with respect to how and when a taxpayer can take a loss from a pass-through entity

A basic understanding of the tax rules relating to individual income tax

None

Yes

Yes

Varies by state. Check back soon for details