GROUPING FOR PURPOSES OF SECTIONS 469/1411/199A is a 4-hour video conference led by Lucien Gauthier, Esq., LL.M., CPA.
The proper grouping of activities can be extremely important for purposes of both sections 469 and 1411 (the 3.8 tax on NII). Topics include a detailed analysis of the rules for grouping that are contained in Reg. 1.469-4 and all of the judicial decisions and administrative pronouncements involving grouping including: Eugene B. Glick, Stephen A. Gregg, Sidney C. Shaw, Vincent S. Sciabica, Eugene J. Schumacher, Tony R. Carlos, Leroy Candelaria, TAM 200747018, Carlos A. Senra, CCA 201411025, Scott Wesley Williams, Jose A. Lamas, Roy E. Stanley, TAM 201634022, and Stephen P. Hardy; the application of grouping for purposes of sections 469, 1411 and 1.1411-4(g)(6) including the "fresh start" Reg. 1.469-11(b)(3)(iv); Rev. Proc. 2010-13 regarding the requirement to report new groupings and additions to existing groupings for tax years beginning on or after 1/25/2010; the difference between grouping under Reg. 1.469-4 and aggregation under Reg. 1.469-9 and a special chart depicting these differences; the use of Form 8275 to disclose issues involving uncertain tax positions regarding grouping; the lack of an interrelationship with Section 199A; and much more.
This is a live, interactive Zoom video conference with Q & A throughout the seminar.
BONUS: 30-minute pre-game warm-up to jump on early to ask questions about any topic!