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Code § 199A Safe Harbor for Rental Real Estate; Partnership Structural Issues; Sale of Intangible Assets

4.2 (83)

Steve Gorin, CPA

Thompson Coburn LLP

Wednesday, March 11, 2020 | 11:30 AM EDT

  • CPA
  • EA

1.5 Credits


Subject Area


Upcoming Webinars

Course Description

This webinar focuses on application of the IRC Section 199A deduction as it pertains to clients who own rental real estate. For clients who own rental real estate, the IRS has provided guidance with a safe harbor under Notice 2019-07.  The grouping rules here are quite different from the grouping rules under IRC Section 469. Planning opportunities as well as pitfalls will be discussed. Any late breaking developments in this area will also be discussed in this webinar. The IRS issued a long-awaited safe harbor for when real estate rental qualifies as a trade or business for purposes of the 20% deduction for qualified business income under IRC § 199A.

In this webinar we will review the rules for rental under Code § 199A and explain how the new safe harbor fits into the framework. We will explore a smattering of recent developments in partnership tax, such as final regulations discussing employee vs. partner in tiered structures, the nature of interest expense when a partnership interest changes hands, and the effect of changes on inside basis when an interest in a tiered structure changes hands. Finally, we will discuss the income taxation of intellectual property and other intangibles in light of 2017 tax reform.

Learning Objectives

  • Strategy for qualifying real estate rental as a trade or business under IRC § 199A independent of the safe harbor.
  • How the new safe harbor for real estate changed from its proposed terms and the extent to which the safe harbor helps.
  • How recently finalized regulations treat compensatory payments from disregarded entities to partners in the parent partnership.
  • What those regulations intentionally did not address that provide opportunities for tiered partnership structures.
  • How to determine the deductibility of interest expense incurred by a partnership and how distributions from a partnership affect that determination.

Who Should Attend?

  • Accountant
  • Accounting Firm
  • Accounting Practice Owners
  • Auditors
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • CPA in Business
  • Enrolled Agent
  • Entrepreneurial Accountant
  • Entrepreneurial CPA
  • Finance Director
  • Finance Pros
  • Others
  • Outsourced CFO
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Director (Industry)
  • Tax Firm
  • Tax Practitioners
  • Tax Pros
  • Young CPA


    [no_of_record] => 83
    [average] => 4.2048




This course really gave me a lot of information in a short period of time. Condensed but not too heavy. Clear and well presented. At no point was I bored or feeling like he rushed too quick


The information was presented at a reasonable pace. The displays were easy to read, very informative and answered any questions, which came to mind . Also, really love the manual and the wealth of information provided


The presenter was very lively and gave us many examples of issues to help show us the material in a way we can apply it. Steve explained so we could easily understand the subject matter.


The webinar was more to the point than the live classes I have been to. I was able to attend this webinar on my phone while commuting! I’m glad that this webinar functioned well on my phone as it functions on my laptop.


Very informative webinar. The material was well presented and and certainly clarified many questions on a little-known but valuable subjects ! I also liked the entire query session.


I am thoroughly impressed with Mr. Steve's knowledge and his generosity in sharing it. The topics coverage was very complete.