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On Demand

The §465 At-Risk Rules: Important Concepts - QAS Self Study


Total Credits: 3.0 including 3.0 CPE

Average Rating:
   5
Categories:
Flow-Through Taxation |  Tax Planning |  Partnership Tax Planning |  LLC Tax Planning |  S Corporation Tax Planning
Faculty:
Charles R. Levun |  Michael J. Cohen
Course Levels:
Basics
Duration:
3 CPE Credit Hours
Format:
Audio and Video
License:
Access for 1 year(s) after purchase.



Description

Learning Objectives & Overview

Learning Objectives

After completing this course, you will be able to:

• Differentiate between the basis rules and the at-risk rules.

• Determine a taxpayer’s amount at risk on Schedule K-1 of a flow-through entity’s income tax return.

• Identify when a guarantee of partnership debt provides the guarantor with an amount at risk and when it does not.

• Determine whether nonrecourse debt used to acquire real property meets the qualified nonrecourse debt requirement necessary to include the debt in a partner’s amount at risk.

• Ascertain when aggregation of activities is permissible to use an excess amount at risk from one activity to increase a shortfall in an amount at risk of a less generating activity.

Overview

This QAS Self Study program is designed for tax professionals of all levels of experience and for people in the accounting and legal professions.

The program begins with the at-risk rule basics and how to compute and report a taxpayer's amount at-risk. 

The program then addresses: (1) the impact of debt guarantees; (2) borrowing from someone who has an interest in an activity other than as a creditor; (3) what is the activity of holding real property for purposes of classifying nonrecourse debt as "qualified nonrecourse debt"; and (4) when activities can be aggregated.

CLE Credit 

Each state has its own Continuing Legal Education (CLE) credit requirements.  Tax Forum has not applied for CLE credit in any state for its Self-Study programs. No assurance can be provided that any Self-Study program will qualify for CLE credit in a state. If you require CLE credit, we suggest you contact the applicable state bar association (or other governing body) on how you may request CLE credit for attending one of Tax Forum’s Self-Study programs.

 

Revision date: 1/2/24; Reviewed by Michael J. Cohen

 

 

Handouts

Faculty

Charles R. Levun's Profile

Charles R. Levun Related Seminars and Products

Tax Forums


Charles R. Levun, JD, CPA, is a partner in the Chicago-area law firm of Levun, Goodman & Cohen, LLP. He is also the consultant to the Wolters Kluwer, CCH, Partnership Tax Planning and Practice Guide, for which he was the co-author of the monthly “Partner’s Perspective” column for its entire term of publication (1987-2020), and was an Adjunct Professor of Law at the Illinois Institute of Technology Chicago-Kent Graduate Tax Program (1985-2019 program termination) and Editor-in-Chief of the Journal of Passthrough Entities for its entire term of publication (1998-2019).

Mr. Levun received a JD from the University of Chicago Law School and a BS in Accounting from the University of Illinois. He is a past chair of the Partnerships and LLCs Committee of the American Bar Association’s Section of Taxation, the Chicago Bar Association’s Federal Taxation Committee and the Federal Taxation Section Council of the Illinois State Bar Association, and is a Fellow and past Regent in the American College of Tax Counsel. Mr. Levun has been chair of the faculty and co-sponsor of the Tax Planning Forum and the "Fundamentals of Flow-Through" Tax Seminar since their inception.


Michael J. Cohen's Profile

Michael J. Cohen Related Seminars and Products

Tax Forums


Michael J. Cohen, JD, LLM, MBA, CPA, is a partner in the Chicago-area law firm of Levun, Goodman & Cohen, LLP. Mr. Cohen received a JD and an LLM in Taxation from the Illinois Institute of Technology Chicago-Kent College of Law. He holds an MBA in Finance from DePaul University and a BS in Economics from the University of Pennsylvania, Wharton School of Finance and Commerce.

Mr. Cohen was the Associate Editor-in-Chief of the Journal of Passthrough Entities for its entire term of publication (1998-2019) and was the co-author of the monthly "Partner's Perspective" column for its entire term of publication (1987 - 2020) that accompanied the Wolters Kluwer, CCH, Partnership Tax Planning and Practice Guide. He has been co-chair of the faculty and co-sponsor of the Tax Planning Forum and the "Fundamentals of Flow-Through" Tax Seminar since their inception.


Additional Info

Learning Objectives

After completing this course, you will be able to:

• Differentiate between the basis rules and the at-risk rules.

• Determine a taxpayer’s amount at risk on Schedule K-1 of a flow-through entity’s income tax return.

• Identify when a guarantee of partnership debt provides the guarantor with an amount at risk and when it does not.

• Determine whether nonrecourse debt used to acquire real property meets the qualified nonrecourse debt requirement necessary to include the debt in a partner’s amount at risk.

• Ascertain when aggregation of activities is permissible to use an excess amount at risk from one activity to increase a shortfall in an amount at risk of a less generating activity.


Getting Started

Handout: Please download the searchable PDF by clicking "Handouts" in the top navigation above.  This will be helpful for the final exam.  A GLOSSARY is included to provide insights into any new terms.

Notes: The navigation tab just to the left of the Handouts tab, provides a handy notes area for jotting down key ideas for the final test or for your future review and insights.  You can also email them to yourself with the "email button." Don't forget to save them before you leave that screen.

Quizzes: Review questions will pop up periodically throughout the program. You must take these quizzes to advance the program. They do not count towards the final test. If you get the incorrect answer, you will receive a hint.  You can then select a different response to learn the correct answer.

Final Test: You have three attempts to pass. You will need to get a 70% score to pass.  There is no partial credit.

Certificate: Once you pass the test, this will be accessible on your account page. 

Quick Search: Both the downloadable course PDF and the course transcript are readily searchable.  

• The downloadable materials can be accessed via the blue "handouts" link on the "My List" section of your Customer Profile Page (to the right of the program "launch viewer" button) as well as from the top navigation panel when viewing the program. The materials can be searched either by using the hyperlinked table of contents or by using the search bar on the very top right of the downloaded PDF file.  To use the search feature, simply enter the term you want to search for into that bar and all instances of that term will be highlighted in the PDF, as well as listed on the far left panel.

• The transcript, which can be found on the far right side of the top navigation panel when you are viewing the program, has a quick search bar at the top. Simply enter the term you want to search for and all instances of that term will be highlighted in the transcript.

Help and Support: On the top right of the navigation panel, you will see HELP navigation. This will connect you to CE21's (the platform's) support.  To connect to Tax Forums, please send email to support@taxforums.com. Alternatively, you can visit your account-level page and click Contact Us to access the contact form on the Tax Forums website.

 

 

 


Quick-Search

Both the downloadable course PDF and the course transcript are readily searchable.  

• The downloadable materials can be accessed via the blue "handouts" link on the "My List" section of your Customer Profile Page (to the right of the program "launch viewer" button) as well as from the top navigation panel when viewing the program. The materials can be searched either by using the hyperlinked table of contents or by using the search bar on the very top right of the downloaded PDF file.  To use the search feature, simply enter the term you want to search for into that bar and all instances of that term will be highlighted in the PDF, as well as listed on the far left panel.

• The transcript, which can be found on the far right side of the top navigation panel when you are viewing the program, has a quick search bar at the top. Simply enter the term you want to search for and all instances of that term will be highlighted in the transcript.