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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Section 163(j) and the CARES Act: Special Partnership Rules, International Tax and U.S. State Tax Implications

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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Description

The CARES Act amended Section 163(j) of the Internal Revenue Code, significantly impacting taxpayers, partnerships, and international transactions. Tax professionals must understand critical tax rules and calculations for purposes of the business interest expense limitation and implement effective planning methods for taxpayers.

Under the 2017 tax reform bill, Section 163(j) placed limits on the deductibility of interest in a variety of situations, creating significant tax consequences for many partnerships. The recently amended Section 163(j) under the CARES Act allows taxpayers to deduct more business interest expense for the 2019 and 2020 tax years by increasing the adjusted taxable income (ATI) from 30% to 50% and allowing the carryback of net operating losses (NOLs) up to five years. Tax advisers to partnerships need a clear understanding of the impact of the amended rules on partners and to avoid unanticipated tax costs.

Amendments to Section 163(j) by the CARES Act impact both international and state tax planning and reporting. The ability to elect out of the increase in the ATI limitation or not elect to use 2019 ATI for the 2020 year, requires careful consideration for taxpayers for purposes of the base erosion and anti-abuse tax (BEAT) and the interaction of the NOL rules and current international tax laws. The new rules may also cause state tax issues for taxpayers in states that conform to the IRC in effect on a specific date.

Listen as our panel discusses new special partnership rules and the impact of the changes to Section 163(j) under the CARES Act on international and U.S. state taxes.

Presented By

Andrew L. Howlett
Member
Miller & Chevalier

Mr. Howlett practices in the area of federal income tax with an emphasis on tax planning, tax-related transactional matters and tax controversy. He provides counsel on domestic and cross-border corporate tax issues, including advice on asset and stock purchases, joint ventures, mergers, recapitalizations and spin-offs. He also advises individuals, and has substantial experience with the IRS’s voluntary disclosure program. He has a substantial pro bono practice, including assisting 501(c)(3) organizations and individuals with a broad range of tax issues.

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Charles Kaufman
Managing Director
KPMG Law, LLP

Mr. Kaufman’s practice includes advising clients regarding transactions involving the taxation of partnerships, real estate investment trusts, and other pass-through entities. He advises private equity funds and tax-exempt entities in their investment activities and has experience advising both the sponsors of and investors in all types of private investment vehicles. Mr. Kaufman has advised clients with respect to numerous real estate transactions, corporate joint ventures, project finance transactions, securitization transactions, partnership restructurings and workouts, and cross-border financings and investments. In addition, he advises financial institutions in structuring and implementing structured financing and derivatives transactions.

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Bradley R. Wilhelmson
Managing Director
KPMG Law, LLP

Mr. Wilhelmson practices in the firm’s State and Local Tax (SALT) practice and serves as a dedicated resource for the firm’s asset management and real estate clients assisting them on structuring, tax planning and compliance. Mr. Wilhelmson is KPMG’s primary tax technical resource for Illinois and Wisconsin taxes and advises clients on income, transactional, and franchise taxes. He also specializes in investor related state tax issues, including individuals and trusts. Mr. Wilhelmson works extensively on state nonresident withholding tax issues for large multiple-tier structures, and on SALT partnership tax issues, tax controversies and provisions for pass-through entities. He has authored articles and has been quoted in various tax publications, and additionally is a regular presenter on SALT issues at conference and training events.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, June 25, 2020

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Section 163(j) overview, CARES Act changes to Section 163(j)
  2. Special partnership rules
  3. International tax impact
  4. State tax impact

The panel will review these and other key issues:

  • The impact of the CARES Act on Section 163(j)
  • Critical provisions of Rev. Proc. 2020-22
  • Increase of ATI limitation for partnerships
  • Using pre-CARES Act Section 163(j) rules in the context of the BEAT
  • Potential compliance issues based on state conformity
  • Specific exceptions to the application of new Section 163(j)
  • How to calculate ATI for purposes of determining deduction limitations

Learning Objectives

After completing this course, you will be able to:

  • Recognize the impact that the CARES Act provisions have on IRC 163(j)
  • Identify critical takeaways of Rev. Proc. 2020-22 as applied to pass-through entities
  • Ascertain the principal issues in using pre-CARES Act Section 163(j) rules in the context of the BEAT
  • Understand potential state tax issues of IRC 163(j) as amended by the CARES Act
  • Identify the exceptions that allow a business to avoid the consequences of IRC 163(j)
  • Ascertain whether a business is eligible to be exempt from IRC 163(j) under the complex small business rules
  • Identify the exceptions that allow a business to avoid the consequences of IRC 163(j)
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of partnership and corporate structure, agreements and liquidation, including capital accounts, debt allocation and distributions; familiarity rules governing transactions between a partnership and its partner(s); familiarity with deferred foreign-source income, earnings and profits, controlled foreign corporations, specified foreign corporations, and repatriation of deferred foreign earnings.

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .