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UID:590287kak
DTSTAMP:20260501T013018Z
DTSTART:20260608T120000Z
DTEND:20260608T150000Z
SUMMARY: Advanced Partnership Tax: Navigating the New Era of Allocations and Self- Employment Risks
DESCRIPTION: *** Save 15% on this event when you use the code SAVE15 at checkout ***\n  \nAs partnership structures grow increasingly complex\, tax practitioners must move beyond basic "percentage-based" thinking to master the technical mechanics that ensure tax follows the economic deal. This course provides a deep dive into three of the most critical and high-risk areas in modern partnership taxation: the shift from traditional "Layer Cake" allocations to distribution-driven "Target" models\, the complex traps of phantom income and capital shifts\, and the rapidly evolving landscape of self-employment tax for partners.Participants will explore the "Substantial Economic Effect" (SEE) safe harbor and understand why modern Target Capital Account provisions almost universally fail its mechanical requirements. We will analyze how to defend these "forced allocations" under the "Partner’s Interest in the Partnership" (PIP) standard and the "Economic Effect Equivalence" test.The session also tackles the "Great Divide" in self-employment tax\, contrasting the Tax Court’s "functional analysis" test with the Fifth Circuit’s recent return to a strict "limited liability" standard in Sirius Solutions\n 
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