Final Regulations and Other Recent Guidance under Code § 199A; Life Insurance Income Tax Developments
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Course Details

Overview of Topics

  • Proposed Regulations under the Transfer-for-Value Rules3 mins
  • Impact beyond Reportable Policy Sales6 mins
  • Split-Dollar Economic Benefit Arrangement Under Reg. § 1.61-2212 mins
  • Code § 199A Deduction for Qualified Business Income19 mins
  • Types of income and Activities Eligible for Deduction39 mins
  • Aggregating Activities for Code § 199A40 mins
  • Specified Service Trade or Business and SSTB Anti-abuse Rules62 mins
  • Effect on Losses from Qualified Trades or Businesses on Code § 199A Deduction66 mins
  • What are the rules for Real Estate as Qualified Business Income?68 mins
  • Understanding the point of view for Real Estate Safe Harbor and Aggregation70 mins
  • Key information on Multiple Trust Rules88 mins

Course Description

The government has released 2019 final regulations (changing and finalizing 2018 proposed regulations), 2019 proposed regulations, and other official guidance regarding the 20% deduction for qualified business income from pass-through entities, as well as regulations attacking multiple trusts created to avoid federal income tax.

We will discuss planning tips that may affect business structure and irrevocable tax elections, including special issues touching upon real estate or separating businesses from contaminated income. Separately, we will briefly mention some life insurance income tax issues, including proposed regulations under the transfer-for-value rules and a case involving the treatment of compensatory split-dollar arrangements.

Learning objectives

  • How separating business operations can help avoid rules that cause gross-receipts of as little as 5% or 10% of gross receipts from specified service trades or businesses to disqualify an entire business line from being qualified business income.
  • How relevant pass-through entities (RPEs) can aggregate businesses and whether they should do so.
  • How the rules governing trusts, under Code § 199A and other provisions of tax law, changed from the proposed regulations to the final regulations and what you should do when creating a trust that may save income tax.
  • How the final regulations eliminated the proposed regulations’ poor provisions on business formation and inside basis step-up and replaced them with more appropriate rules.
  • How structuring real estate entities affects whether their activities rise to the level of a business and how that structure affects the ability to use the safe harbor for real estate under Notice 2019-7.

About Presenter

Steve Gorin, CPA

Advisor,Thompson Coburn LLP

sgorin@thompsoncoburn.com

Steve has drafted trusts and a full range of estate planning documents for clients to help grow, preserve, and transmit their family wealth. He has also drafted organizational documents for limited liability companies, corporations, and partnerships to implement their owners' wishes regarding current and future control and transmission, including bringing in new owners and facilitating exit strategies. 

Steve enjoys helping clients structure their affairs to achieve their achieve their personal, business, and financial goals while trying to reduce the drag that taxes impose on them. His firm provides full service to businesses; however, he also act as counsel on specialized matters while cooperating and facilitating the continued involvement of an existing legal, accounting, and financial services team. Steve maintains his CPA license but prefer to refer income tax returns to practicing CPAs.

Steve Gorin is former president and an ongoing contributor to strategic initiatives of Covenant Place, a senior affordable housing community with a groundbreaking model for integrated residents with the surrounding community and facilitating holistic services to enrich their lives. 

To know more about Steve Gorin, kindly click on the link below:

http://thompsoncoburn.com/people/steve-gorin



For almost 90 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. With more than 380 lawyers and 40 practice areas, we serve clients throughout the United States and beyond. Whether helping with a real estate or employment issue, navigating a complex acquisition or defending a product or service in litigation, we have the knowledge and resources to meet any legal need.

Here's a link to the free resources that Thompson Coburn has to offer:

https://www.thompsoncoburn.com/insights/blogs/business-succession-solutions/about

Review Questions

  • Question 1 : 00:15
  • Question 2 : 00:30
  • Question 3 : 00:45
  • Question 4 : 01:02
  • Question 5 : 01:25
  1. The acquisition of an interest in a life insurance contract, if the acquirer has no substantial family business or financial relationship with the insured apart from the acquirer’s interest in such a life insurance contract is also known as ____.
  2. Mrs. Melanie is a shareholder and an employee of Zook Investment Corporation. With reference to the split-dollar economic benefit arrangement if she is liable to receive benefits of her policy which one of the following is true?
  3. Which one of the following is true for a relevant pass-through entity?
  4. According to the SSTB Anti Abuse Rules, which one of the following is true?
  5. Which one of the following reduces QBI?
  1. Which one of the following is the correct formula for wage limitation? (A) 50% of the W-2 wages with respect to the qualified trade or business (B) 25% of W-2 wages with respect to the qualified trade or business and 2.5% of the unadjusted basis immediately after acquisition of all qualified property.
  2. Ms. Mona is an S corporation employee and employee stockholder. If she received the benefits of her insurance policy, which one of the following would be true?
  3. • According to Code §199A deduction for qualified business income which one of the following is false?
  4. Which one of the following must be determined by an RPE?
  5. According to the de minimis rule, if trade or business has gross receipt of less than ______, it does not qualify to be an SSTB if ___% of its gross receipts are attributable to the performance of SSTB services.
  6. Manfred & company providing accounting and tax service splits into Manfred Accounting and Manfred Tax Consulting services though continues to utilize the same building that was used by the Manfred and Company. Which one of the following is true for them?
  7. Which one of the following is a QBI?
  8. Which one of the following records is required to produce to have a Real Estate Safe Harbor benefits?

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Reviews

3.9
(8)
38%
13%
50%
0%
0%
  • DS
    Dawn Sabol , CPA, EA
    Dec 10th 2019
    Steve's expertise in the tax law is unparalleled. With certain simple tricks he helped me solve some of the things I was facing difficulty with. Turns out to be a technical understanding difference. I thank him for his inputs.
LA
Lori Albosta , EA
Couldn't figure out how to view slides outside of video.
RO
Robert Offerman , CPA
very good

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  • Cost $9
  • CPE Credits 1.5
  • CE Credits 1
  • IRS Course ID GEHNZ-T-00097-19-S
  • CTEC Course ID 6273-CE-0072
  • Subject Area Taxes
  • Course Level Basic
  • Instructional Method QAS Self Study
  • Prerequisites None
  • Advanced Preparation None
  • Recorded Date November 21 ,2019
  • Published Date November 21 ,2019
  • Who should attend? Enrolled Agent Finance Pros Tax Attorney Tax Practitioners Accountant Others CPA - Small Firm CPA - Mid Size Firm Accounting Firm Tax Pros CPA (Industry) Auditors Tax Firm Young CPA CPA in Business Entrepreneurial CPA Outsourced CFO Tax Accountant (Industry) Accounting Practice Owners Finance Director Entrepreneurial Accountant
  • Handout Material Download
  • Key Terms Download

On-Demand Webinars

2021 Annual Federal Tax Refresher Course
Wednesday, July 08, 2020 View Details/Register
Segment Reporting – A Detailed Review
Thursday, August 06, 2020 View Details/Register
Goodwill Impairment Testing
Thursday, August 06, 2020 View Details/Register
Segment Reporting Basics
Thursday, August 06, 2020 View Details/Register
Goodwill Impairment Basics (1 Hour)
Thursday, August 06, 2020 View Details/Register
Revenue – Five Steps to Recognition
Wednesday, July 29, 2020 View Details/Register
GUIDE TO DEPRECIATION UNDER THE TCJA
Wednesday, July 29, 2020 View Details/Register
PAYROLL FRAUD INFORMATION AND DISCUSSION
Wednesday, July 29, 2020 View Details/Register
Forecasting in a Time of Uncertainty (COVID-19)
Tuesday, July 28, 2020 View Details/Register
TAX IMPLICATIONS AND PLANNING DUE TO COVID-19
Tuesday, July 28, 2020 View Details/Register
UBIT Under The TCJA
Tuesday, July 28, 2020 View Details/Register
Tax Planning Under Tax Cuts & Job Act : 10 Tips to Reduce Taxes for your Clients
Tuesday, July 28, 2020 View Details/Register
Tax Consequences on the CARES Act – Overview of major tax issues from the CARES Act and related notice including planning tec
Monday, July 27, 2020 View Details/Register
CECL Overview
Monday, July 27, 2020 View Details/Register
Accounting for Business Combinations Overview
Monday, July 27, 2020 View Details/Register