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Stephen A. Beck

About this Webinar

Overview

This presentation will discuss the differing federal income tax treatment from granting compensatory capital and profits interests. This presentation will also discuss the differing treatment of compensatory profits interests under the existing authority – i.e., Revenue Procedures 93-27 and 2001-43 – as opposed to the 2005 Proposed Regulations. In addition, this presentation will address provisions that should be included in Partnership Agreements to ensure the tax-free grant of compensatory profits interests. Lastly, this presentation will discuss the conceptual theory underlying a “crystallization” of profits interests and the existing authority addressing whether a “crystallization” may be conducted without triggering a taxable event.

Key Topics

  • Learn the federal income tax rules governing the grant of compensatory capital interests and compensatory profits interests in partnerships.
 


  • Learn the differences between the tax treatment of compensatory profits interests under Revenue Procedures 93-27 and 2001-43 and the 2005 Proposed Regulations.
  • Learn the key provisions that should be included in partnership agreements to facilitate the tax-free grant of compensatory profits interests.
  • Learn the legal and tax principles underlying the "crystallization" of partnership profits interests and the circumstances under which a crystallization may be accomplished without triggering a taxable event.
  • Learn of recent developments and existing authority affecting the taxation of compensatory partnership interests and the practical implications for partnership structuring and compensation planning.
 
 

Details

Course Level: Intermediate
Prerequisite:
None
Cost: Free

CPE and MCLE Credit Info:
Course Number: 174330346
CPE Credit: 1.20 Hrs.
MCLE Credit: 1.00 Hr.

CFP Credit Info:
CFP Program ID: 351601
CFP Credit: 1.00 Hr.

This Event Begins in:

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About the Speaker

Stephen A. Beck, J.D., LL.M.

Partner

Mr. Beck is a Board Certified tax attorney who provides Federal income tax and Texas franchise and sales tax advice to businesses of all types and sizes, including Subchapter C corporations, Subchapter S corporations, partnerships, limited liability companies, and entities disregarded for Federal income tax purposes. He advises on tax issues arising during all phases of business operations, including formation, restructuring of ownership interests, acquisitions, dispositions, mergers, consolidations, liquidations, international transactions, issuance of deferred and equity compensation, and business succession planning. He represents businesses and entrepreneurs in a broad range of industries, including professional services, manufacturing, technology, oil and gas, and real estate. He also advises tax-exempt organizations under Section 501 of the Internal Revenue Code.

Mr. Beck also represents individuals, businesses, and estates in tax related controversy matters, including Internal Revenue Service audits, appeals, and litigation in Federal courts, including the U.S. Tax Court and Fifth Circuit Court of Appeals. He also represents taxpayers in franchise and sales tax disputes with the Texas Comptroller of Public Accounts.

Mr. Beck is Board Certified in Tax Law by the Texas Board of Legal Specialization. He has served as an adjunct law professor at Southern Methodist University Dedman School of Law, where he taught Corporate Income Taxation. He has also served as the Chairperson of the Dallas Bar Association’s Peer Assistance Committee and Co-Chair of the Texas Bar Tax Section Partnership and Real Estate Committee. Mr. Beck was admitted to practice in Texas in 1998 and the District of Columbia in 2000.

Read his full bio here. You can contact Mr. Beck at 214-744-3700 or by email at sbeck@meadowscollier.com.

About Meadows Collier

At Meadows Collier, we are dedicated to supporting continuing education of tax professionals including CPAs, CFPs, and legal experts. We offer free monthly webinars and presentations that provide CPE, MCLE, and CFP credits where applicable. Most firm lawyers hold an LL.M. in Taxation and/or are Board Certified in Tax Law by the Texas Board of Legal Specialization. These free webinars cover a wide array of topics relevant to CPAs, business leaders, legal professionals, and tax specialists. Our webinar topics include federal and state tax updates, IRS enforcement and initiatives, estate planning, corporate tax issues, tax controversy and litigation, and more. Stay informed about the latest developments and gain valuable knowledge from industry leaders. Sign up today to enhance your expertise and navigate the evolving economic landscape with confidence. Tax professionals can rely on Meadows Collier for high quality continuing education.

Founded in 1983, Meadows Collier is a nationally recognized law firm based in Dallas, Texas, specializing in all areas of taxation. Our expertise spans a wide range of complex tax and business matters, including federal and state tax issues, white-collar criminal defense, government regulatory defense, cryptocurrency and digital asset management, wealth planning, corporate law, real estate transactions, and other commercial legal needs. We represent both businesses and individuals in high-stakes litigation, providing solutions for the most challenging tax situations. Tax professionals trust Meadows Collier for comprehensive legal support and expert tax solutions.