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The Tax Cuts and Jobs Act added Section 461(l) to the Internal Revenue Code, limiting losses previously available. To the extent a taxpayer has an "excess business loss" for the tax year under Section 461(l), that portion of the taxpayer's overall loss becomes a net operating loss (NOL) carried forward to future tax years and subject to the new rules that govern NOL generated after 2017. Many owners of S corporations, partnerships, and limited liability companies are now subject to numerous loss limitation provisions. This program covers each loss limitation provision and how they relate to each other, focusing particular attention on Section 461(l).
Tax practitioners who anticipate advising clients regarding this complex provision
- Apply the new loss limitation provisions under Section 461(l) to client situations
- Determine how the other loss limitation provisions interrelate with one another and with the new loss limitation provisions under Section 461(l)
- Understand how the new net operating rules work for 2018 through 2025
- How the new Section 461(l) loss limitation provisions work
- The new net operating loss rules and how they relate to Section 461(l)
- Threshold amounts for limitation
- Determination of a taxpayer’s basis in a pass-through entity
- Suspended losses and deductions due to basis limitations
- How at-risk rules operate to limit loss deductions
- Passive activity loss rules that suspend losses
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