Date: November 26th 2024

Time: 1pmET | 12pm CT | 11am MT | 10am PT

Duration: 120Minutes

Description:

In June 2024, the U.S. Supreme Court ruled unanimously in *Connelly v. United States*, concluding that life insurance proceeds used to fund a redemption agreement in violation of IRC §2703 must be included in the business’s valuation. Following this ruling, along with the recent *Huffman* case, it has become increasingly advisable to avoid using life insurance-funded redemption agreements when §2703 applies. This webinar will explore the implications of the *Connelly* decision, offering guidance on structuring cross-purchase agreements using life insurance LLCs as a more effective alternative.

The session will also cover the recent ruling in *ES NPA Holding, LLC v. Commissioner* (T.C. Memo. 2023-55), which approved the nontaxable issuance of a profits interest. We will discuss the partnership income tax issues related to profits interests, including basis shifting, and how a new, potentially limited reporting window could affect such transactions.

Finally, the webinar will address the Federal Trade Commission’s (FTC) new prohibition on non-compete agreements, including key deadlines and how businesses can protect their intellectual property in the wake of these regulatory changes.

Learning Objectives:

• Evaluate when to use life insurance-funded agreements versus cross-purchase agreements and understand how to implement each structure
• Understand the nontaxable issuance of profits interests in new partnerships and how this differs from shifting interests among existing partners
• Analyze IRS challenges to basis shifting transactions and recognize the potential short deadlines for reporting, including routine and non-abusive basis adjustments
• Review the FTC’s new ban on non-compete agreements and explore strategies businesses can use to protect their intellectual property in light of these changes

Credits and Other information:

• Recommended CPE credit – 2.0
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 120 Minutes

Who Will Benefit:

• CPA
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
• Financial planners

About Our Speaker

Steve Gorin, CGMA, CPA, J.D. Steve has drafted trusts and a full range of estate planning documents for clients to help grow, preserve, and transmit their family wealth. He has also prepared organizational documents for limited liability companies, corporations, and partnerships to implement their owners’ wishes regarding current and future control and transmission, including bringing in new owners and facilitating exit strategies.

Steve enjoys helping clients structure their affairs to achieve their personal, business, and financial goals while reducing the drag that taxes imposed on them. His firm provides full service to businesses; however, he also acts as counsel on specialized matters while cooperating and facilitating the continued involvement of an existing legal, accounting, and financial services team. Steve maintains his CPA license but prefers to refer income tax returns to practicing CPAs.