A LISI "Lunch-n-Learn" series
The 199A - 2019 SixPack Program
Section 199 A Planning from A to Z,
with an Emphasis on Creative and Practical Planning Applications
199 A Planning from A to Z,
Featuring attorneys Alan Gassman and Brandon Ketron of Gassman, Crotty & Denicolo, P.A.
This series includes Unlimited Viewing of the the 6 Recorded Webinars below plus the Printable PDF Slide Deck for each of the 6 webinars described below.
Part One - Primary Rules Under Section 199A (37 minutes run time)
This module covers the primary mechanical and definitional rules that are fundamental to all Section 199A and related planning, including the following:
- Qualified Property and Wage Definitions
- What it takes to be an active trade or business.
- Definitions and main exceptions for Specified Service Trade or Business Categories under the Regulations.
- Aggregation and related party rules.
Part Two - What the Final Regulations Changed (29 minutes run time)
This module covers all significant changes and clarifications found in the Final Regulations that were issued on February 4, and explains the primary differences between the Final and Proposed Regulations, while introducing concepts that are used in subsequent modules. These include:
- SSTB Rules
- Conversion of Employees to Independent Contractors.
- 754 Elections and guaranteed payments under partnerships.
- When SSTB income and Non SSTB Income can be disregarded separated or all treated as SSTB or Non SSTB income.
- And much more.
Part Three - Trusts and Trust Planning Under Section 199A (32 minutes run time)
This Module covers the SSTB and wage or qualified property limitation situations where high earner taxpayers can use trusts to save income taxes both under 199A and other tax provisions, and how to navigate around the anti abuse rules and the
opportunities that they don not prevent. Discussion includes the following:
- When complex trusts can be used, and when not under the new anti abuse rules.
- How Distributable Net Income works with the $157,500 threshold.
- Other advantages and disadvantages of complex trusts.
- Use of Section 678 Trusts or ownership by lower income family members.
- What entities that perform services for SSTB's can be owned by the above trusts or individual.
- New rules on Multiple Trusts.
- How to handle Electing Small Business Trusts and Qualified Sub chapter S Trusts, and what other entities can own S corporation stock.
Part Four - Planning for Health and Other Professional Businesses and Practices (37 minutes run time)
This module explains the planning considerations that apply for medical and other professional practices, along with planning opportunities and the following:
- In depth discussion of the definition of Health Services under the Final Regulations.
- General income tax planning outside or consistent with Section 199A.
- Rental properties that are used SSTB's.
- Using management, factoring and other trade or business entities with related and unrelated parties.
- How asset protection and estate tax planning can be addressed with 199A planning in the same structure.
Part Five - Planning with Real Estate Under Section 199A (30 minutes run time)
This module covers both real estate holding entities, real estate professional and a close look at the qualified property rules, and includes the following:
- SSTB definitions in the real estate business.
- Unadjusted Basis Immediately After Acquisition (UBIA) Rules for new acquisitions, 1031 exchanged property, partnership owned property, property conveyed to an S corporation and other basis rules and considerations.
- What it takes to be a trade or business, and the safe harbor for leased property.
- Passive Loss, Employment Taxes.
- 199A's impact on the decision as to whether to convert a vacation home to rental property.
Part Six - Sections 199A & 1202 Creative Planning Strategies for Flow-Through Entities, Contractors and Others (40 minutes run time)
This module reviews the best planning strategies that planners can implement for their clients, including the following:Entity selection under 199A and other factors.
- When to convert an employee to an independent contractor and what it takes under the new Regulations.
- Use of Section 1202 and non Section 1202 C corporations.
- When to pay wages to a spouse or not pay a spouse and choice of whether to be married or not considerations.
- List of strategies to reduce taxable income to be under the thresholds.
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