Canceled - St Louis, MO: Planning Using the Proposed Regulations under IRC ยงยง 199A and 643(f)

Oct 30, 2018 11:30am -
Oct 30, 2018 01:30pm

Event Description



The Missouri Chapter of the American Academy of Attorney-CPAs invites you to:


Planning Using the Proposed Regulations under IRC §§ 199A and 643(f)


Tuesday, October 30, 2018

11:30 a.m. - 2:00 p.m.




Steven B. Gorin

Thompson Coburn LLP

Program Description

In August, the government issued proposed regulations under IRC §§ 199A (20% deduction for qualified business income from passthrough entities) and 643(f) (multiple trusts treated as one trust).  These regulations inform strategic and tactical planning for passthrough entities and trusts, of course containing some favorable and very unfavorable rules. 


Learning Objectives

We will review some basics and then get into the proposed regulations.  You will learn:

  • Wage and unadjusted basis immediately after acquisition (UBIA) limitations.  See how basis step-up in different transfers affects UBIA and why tax-free formation of a business can (unfairly) reduce UBIA.  Consider whether workarounds really help.
  • Relevant passthrough entities (RPEs) and aggregation.  The proposed regulations provide some relief but also do not allow favorable real estate aggregation from the passive loss rules.
  • Specified Service Trade or Business limits.  Say good-bye to "crack and pack."
  • Proposed regulations' attack on trusts.  The government listened to those who touted using multiple trusts to circumvent limitations of 2017 tax reform and seems to have decided that trusts are evil.  Be aware of the government's traps and consider whether you can avoid them.


About the Speaker


Steven B. Gorin

Steve is a nationally recognized practitioner in the areas of estate planning and the structuring of privately held businesses. Lawyers, accountants and business owners regularly look to Steve for fresh, highly knowledgeable insights into the best possible tax and estate planning approaches to their transactions.


Steve crafts estate plans for individuals, keeping in mind their financial security and desire to save income and estate tax. In his work for businesses, Steve helps owners plan for the eventual sale (to co-owners, employees, or third parties)or transfer (to family members), and provides a legal framework for an orderly transition while strategically saving income, transfer, and FICA taxes.


Drawing on his background as an accountant - and his still-current CPA license and Chartered Global Management Accountant credential - Steve structures businesses to achieve business objectives and save income or estate tax. He has helped fledgling businesses organize, thriving businesses restructure to save hundreds of thousands of dollars of income tax when planning a transition to the next ownership group, and mature multi-million or billion-dollar businesses plan tax-saving transfers to the next generation.


Steve is a highly visible member of the ABA's Real Property, Trust & Estate Law Section and the American College of Trust & Estate Counsel, which regularly directs its members to Steve's quarterly newsletter. He has represented both groups in comments to the IRS, the U.S. Treasury, and tax lawmakers.


Click here to read Steve's full biography. 


Date & Time

Tuesday, October 30, 2018 

11:30 a.m. - Registration and Lunch

12:00 p.m. - 1:30 p.m. -  Program

1:30 p.m. - 2:00 p.m. - Questions and Networking



Thompson Coburn, One US Bank Plaza, St. Louis, MO 63101

For directions, email



1.0 credit of Continuing Professional Education (CPE) for Certified Public Accountants (CPA) in Business Law; 1.2 MCLE credit is pending approval with The Missouri Bar. 


Prerequisites: None

Advanced Preparation: None

Program Level: Update

Delivery Methods: Group-Live



$20.00 AAA-CPA Members; $30.00 Non-Members and Guests. Lunch provided. 


Who Should Attend: Attorneys, Certified Public Accountants, Business Professionals


Registration is appreciated by Friday, October 26, 2018


The American Academy of Attorney-Certified Public Accountants, Inc. (AAA-CPA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website:




Event Type:Chapter Meeting
Early registration ends on Oct 07, 2018.
Regular registration starts on Oct 08, 2018 and ends on Oct 29, 2018.
Late registration starts on Oct 30, 2018.