Surgent’s Loss Limitations – A Mechanical Review (SSTX769/24)
Owners of S corporations and partnerships are subject to various limitations on pass-through losses, each with unique rules, applications, and complexities. As many businesses are reporting losses as a result of COVID-19, it is essential for tax practitioners to understand the mechanical aspects of each limitation and how they coordinate to provide effective planning for loss utilization in future periods.
Experienced practitioners who desire a refresher on loss limitations and an analysis of the new rules and less experienced practitioners who desire to learn the basics of all four pass-through loss limitations and their interactions in one course
Understand how the activity of an entity and distributions are handled when basis limitations exist for partnership interest and S corporation stock Analyze at-risk amounts for disallowed losses and demonstrate understanding of how the amount and character of suspended amounts are determined Understand passive loss limitations and how character and the number of suspended losses are determined Analyze excess business loss limitations created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting carryforward amounts
Limitation 1: Basis limitations will be reviewed in detail with computational examples and include insights into similarities and differences between calculations for partnership interests and S corporation stock Limitation 2: Detailed at-risk limitation computational examples will be reviewed, and the mechanical features of partnerships and S corporation activities will be compared and contrasted Limitation 3: Passive loss limitation mechanics will be outlined in detail and discuss computations where there are a mix of entity structures owned by a taxpayer Limitation 4: Excess business losses will be presented from a mechanical perspective
Basic familiarity with loss allowance rules of pass-through entities