• videocam Live Webinar with Live Q&A
  • calendar_month November 17, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparation - Pass Through
  • schedule 110 minutes

Loss Limitations Analysis: Basis, At-Risk, Passive, and NOLs

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About the Course

Introduction

This course will discuss the hierarchy of basis, at-risk, passive activity loss (PAL) limitations, net operating loss (NOL) limitations, and steps to avoid and mitigate the limitation of losses for owners of partnerships and S corporations.

Description

A multitude of limitations exist to delay the deduction of losses by taxpayers. Although most aim to prevent taxpayers' manipulation of losses, there are times when legitimate transactions result in nondeductible losses. Separating these allowed/deductible and unallowed/carried forward losses is complex.

Section 704(d) dictates that partnership losses exceeding basis at year-end must be suspended. The mirror provision for S corporations, Section 1366(d), states that shareholder losses are limited to the shareholder's adjusted basis in the stock plus his loans to the corporation. Excess losses are carried forward indefinitely. Although similar to basis limitations, Section 465 at-risk rules further limit losses requiring that the taxpayer be "at-risk" or personally liable for the amounts claimed as losses. The extent of this personal liability obligation is interpreted differently for shareholders and partners, adding further complications.

A deductible loss must pass through yet another hurdle—the PALs under Section 469. PALs are limited to the amount of passive income reported, so identifying passive income is critical. Understanding the interaction of basis, at-risk, passive, and NOLs is essential for tax practitioners looking to maximize loss deductions for taxpayers.

Listen as our panel of tax experts discusses the interplay of the many restrictions on loss deductions, including structuring opportunities to maximize the amount currently deductible.

Presented By

Robert B. Rowe
Senior Associate
Lippes Mathias

Mr. Rowe focuses his practice primarily on Tax Controversy and Audit Defense, assisting clients with federal income tax issues and federal gratuitous transfer tax issues. Before joining Lippes Mathias, he worked for the Internal Revenue Service’s Office of Chief Counsel in the Large Business and International Tax Division. While with the Office of Chief Counsel, Mr. Rowe represented the IRS in Tax Court and assisted IRS examinations of large businesses and high net worth individuals, with a focus on international (including transfer pricing), large partnership, corporate, private equity, real estate, cannabis, and micro-captive insurance related tax issues. 


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Nathan Sosa, CPA, MST
Manager of National Tax
Hall CPA PLLC

Mr. Sosa is a Manager of National Tax at Hall CPA PLLC. He is a strategic leader overseeing national tax education and compliance initiatives. Mr. Sosa directs complex tax research and technical training programs while providing authoritative guidance on sophisticated tax legislation. He spearheads development of comprehensive continuing education curriculum ensuring adherence to evolving regulatory requirements. 

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Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

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

Date + Time

  • event

    Tuesday, November 17, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Basis

II. At-risk limitations

III. Passive loss limitations

IV. Net operating losses

V. Section 461(l) excess business loss limitation

VI. Planning opportunities

The panel will review these and other notable issues:

  • The appropriate hierarchy for application of loss limitations
  • What constitutes amounts at risk for partnerships and S corporations
  • How can activities be aggregated to avoid PAL limitations?
  • When losses are carried forward, and how are losses applied to different types of income?


Learning Objectives

After completing this course, you will be able to:

  • Ascertain whether inside basis, outside basis, or both are required to be adjusted
  • Identify opportunities to group or aggregate trade and business activities
  • Recognize the requirements for meeting the tax basis capital provisions
  • Ascertain at-risk amounts
  • Determine how the excess business loss is calculated
  • Understand how the rules related to net operating losses are applied
  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and their respective partners and shareholders.


BARBRI, Inc. 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 Barbri-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 .