When Does a Trustee’s Activities
Rise to the Level of “Material Participation”?
(So a Trust’s Business or Rental Losses
Can Avoid the Passive Loss Limitation and
Income Can Avoid the 3.8% Net Investment Income Tax?)
If you’re an attorney advising trustees or a CPA preparing trust tax returns, you now have new guidance - - and powerful planning opportunities - - thanks to the recently released U.S. Tax Court case of Frank Aragona Trust v Commissioner.
You need to know how the landscape for the material participation standard of trusts has changed after the Frank Aragona Trust, including the following:
- How IRC Section 469 and the Regulations thereunder now apply to trusts
- How Section 1411 (NIIT) and the Regulations thereunder now apply to trusts
- A fresh understanding of the Congressional Committee Reports and the legislative history of the material participation standard for trusts
- The combined impact of the applicable case law (including Mattie K. Carter and Frank Aragona Trust) and available IRS guidance (including TAM 200733023, LTR 201029014 & LTR 201317010)
- What are the new, possible planning opportunities
Join us and national renowned CPA and tax expert, Robert Keebler, for a very timely 90-minute program entitled, “Trustee Material Participation After the Frank Aragona Trust Decision”.
- Program Title: Trustee Material Participation After the Frank Aragona Trust Decision
- Speaker: Robert S. Keebler
- Duration: 90 minutes
Purchase
ABOUT THE SPEAKER
Robert S. Keebler
CPA/PFS, MST, AEP (Distinguished)
Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. Mr. Keebler frequently represents clients before the National Office of the Internal Revenue…
IMPORTANT NOTICE REGARDING CE CREDIT
The Ultimate Estate Planner, Inc. and the presenter are not registered Continuing Education Sponsors and this program is not pre-approved for continuing education credit for any state or regulatory agency.
However, please note that each program includes a Certificate of Completion and, depending on the license and the regulatory agency for which governs a participant’s CE credit, some professionals may be able to self-report his or her participation and receive credit. It is the responsibility of the participant to complete any process necessary to seek self-reported CE credit for his or her participation. By registering for a teleconference (or purchasing on On-Demand program), you understand that CE credit is not guaranteed or warranted by the presenter or The Ultimate Estate Planner, Inc.