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Charitable Gifts; LLC or Real Estate as Inventory; ESBT NOL; S Corp. Trust Sale

CHARITABLE GIFTS; LLC OR REAL ESTATE AS INVENTORY; ESBT NOL; S CORP. TRUST SALE

Cost Free
Presentation Length 2.0 hours

Recorded DateNovember 20, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelAdvanced
Course Description

This course discusses many topics including charitable gifts from trusts and bargain sales, when real estate or an LLC interest constitutes inventory, and selected fiduciary income tax issues regarding a trust owning S corporation stock. These topics will be viewed through the lense of various recent court cases.

Regarding charitable issues, Braen v. Commissioner, T.C. Memo. 2023-85, disallowed a bargain sale and is a primer on various substantiation issues. Also, an unreported Tax Court case was settled favorably to the taxpayer when the IRS attempted to disallow charitable contributions authorized after a trust was decanting. The judge’s pretrial order expressing support for the decanting led to the settlement.

Glade Creek Partners, LLC v. Commissioner, T.C. Memo. 2023-82, held that real estate was inventory and described how the taxpayer could have tried to avoid that result. CCA 202309015 argued that the interests in LLCs holding land were inventory under Code § 1221.

Finally, CCA 202335014 clarified an electing small business trust’s deduction of net operating losses, clarifying the scope of CCA 200734019. While on the topic of S corporation trust, this webinar will discuss toggling grantor trust status when the business is sold.


Learning Objectives:


  • Evaluate the affects of recent court cases and legal developments on charitable contributions and real estate taxation

  • Identify how bargain sales affect charitable gifts

  • Define the tax consequences of inventory vs. capital asset

  • Recognize how real estate and LLC interests work as inventory

  • Evaluate electing small business trust income taxation

  • Recognize gain and basis mismatches when toggling grantor trust status when a business is sold

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Thompson coburn llp

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.

Steve Gorin is the former president and an ongoing contributor to Covenant Place’s strategic initiatives. It is a senior affordable housing community with a groundbreaking model for integrated residents with the surrounding community and facilitating holistic services to enrich their lives. 

To know more about Steve Gorin, kindly click on the link below:

http://thompsoncoburn.com/people/steve-gorin

For various free resources Steve offers, see https://www.thompsoncoburn.com/insights/blogs/business-succession-solutions/about

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About Our Presenter

Thompson coburn llp

For approximately 90 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. Whether helping with a tax, estate planning, real estate or employment issue, navigating a complex acquisition or defending a product or service in litigation, we have the knowledge and resources to meet any legal need.


With over 380 attorneys, we have experience in more than 50 areas of the law. Supported by our firm's state-of-the-art technology, lawyers in our Chicago, Dallas, New York, Los Angeles, Southern Illinois, St. Louis and Washington, D.C. offices enjoy a nationwide practice.