Introduction to Partnerships Taxation 2026 (presented by NYU School of Professional Studies)

James A. Gouwar
Charles R. Bogle
Justin S. Cohen
Sean Austin
Charles Kaufman
Alan Kravitz
Ira Aghai
Steven R. Schneider
Matthew Busta
Hannah Richard
Olivia Schomburger
Annet M. Thomas-Pett
James A. Gouwar | Sidley Austin
Charles R. Bogle | Morgan, Lewis & Bockius
Justin S. Cohen | Hughes Hubbard & Reed
Sean Austin | KPMG
Charles Kaufman | KPMG
Alan Kravitz | Hughes Hubbard & Reed
Ira Aghai | Clifford Chance
Steven R. Schneider | Hogan Lovells
Matthew Busta | KPMG
Hannah Richard | Clifford Chance
Olivia Schomburger | Clifford Chance
Annet M. Thomas-Pett | PwC

On-Demand: July 27 - July 29, 2026

19.58 hour CLE

Tuition: $395.00
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Program Summary

 

Three days from formation to winding up

This three-day program is a ground-up introduction to partnership taxation under Subchapter K of the Internal Revenue Code. The program level is basic, with no prerequisite. Faculty come from seven national law and accounting firms, chaired by James A. Gouwar of Sidley Austin.

Day one sets the foundation: choice of entity, formation nonrecognition, beginning capital accounts and basis, and accounting elections. Day two follows the money: nonrecourse allocations, current, liquidating, and disproportionate distributions, and disguised sales. Day three covers transfers of interests, retirement and death of a partner, and the troubled partnership. Recent developments get their own hot topics session.

The program ends by working through a partnership tax return and a sample partnership agreement. Emphasis falls on tax-sensitive provisions: capital account maintenance, book-ups, Section 704(c) allocation methods, and allocation, distribution, and liquidation provisions. You leave with a solid foundation for addressing the intricacies of Subchapter K, from formation through winding up.

Key topics to be discussed:

  • Partnership Fundamentals
    The nature of partnerships and the various legal entities taxed as partnerships, including entity classification and restrictions on partnership status.
  • Partnership Formation
    Contributions of property and services in exchange for partnership interests, nonrecognition on formation, and beginning capital accounts and basis.
  • Operations and Allocations
    Partnership operations and reporting, with emphasis on allocations of income and deductions, including special allocations and nonrecourse allocations.
  • Partnership Distributions
    Current, liquidating, and disproportionate distributions to partners.
  • Partner-Partnership Transactions
    Disguised sales and other transactions between a partnership and its partners, and the relationships between and among partners.
  • Winding Down and Winding Up
    Transfers of partnership interests, retirement and death of a partner, troubled partnerships, and the tax-sensitive provisions of a partnership agreement.

This course is co-sponsored with myLawCLE.

Closed-captioning available

Speakers

James A. Gouwar_FedBarJames A. Gouwar, Esq., Partner | Sidley Austin 

James A. Gouwar is a partner in the Tax, Pensions & Employment group in Clifford Chance’s New York office. His practice concentrates on the tax aspects of structured finance transactions, including mortgage- and asset-backed transactions, cash and synthetic collateralized loan and debt obligations, and real estate mortgage investment conduits (REMICs). He has been involved in the development of innovative securitization structures and has worked with a broad range of financial assets. His experience extends to private equity funds, hedge funds, regulated investment companies, and other pooled investment vehicles.

  • Education & Credentials

Mr. Gouwar earned his B.A. from the University of Denver, his J.D. from the University of Denver College of Law, and his LL.M. in Taxation from New York University School of Law. He is admitted as an Attorney-at-Law in New York.

  • Recognition & Leadership

Mr. Gouwar is ranked Band 2 by Chambers Global 2026 and Chambers USA 2024 in Capital Markets: Securitization: Tax (Nationwide), and was ranked Band 2 by Chambers USA 2022 in the CLOs, CMBS, and RMBS securitization categories. He is recognized as a Leading Individual by The Legal 500 USA 2024 in Tax – Financial Products, with additional Legal 500 USA 2024 recognition in Finance, Structured Finance: Derivatives and Structured Products.

  • Professional Involvement

Mr. Gouwar serves as Chair of the Introduction to Partnerships program at New York University’s Summer Institute in Taxation. He joined Clifford Chance as a partner in 2018.

  • Experience

Mr. Gouwar’s representative matters include securitizations of cellular telephone sale receivables for Verizon Wireless; reperforming, performing, and nonperforming residential mortgage loans for clients including Cerberus/First Key, CarVal/Mill City, and MetLife; GNMA commercial mortgage loan certificates for clients including Credit Suisse, Goldman Sachs, and Morgan Stanley; auto loans and leases for clients including Toyota, Honda, and BMW; student loans for clients including Navient; and marketplace loans sponsored by platforms including Lending Club, LoanDepot, Prosper, Marlette, Upgrade, and Upstart. He has also advised on CLO transactions for managers including Investcorp Credit Management US LLC and Zais Leveraged Loan Master Manager LLC.

 

Charles R. Bogle_FedBarCharles R. Bogle, Esq., Partner | Morgan, Lewis & Bockius

Charles (Chuck) Bogle is a partner in Morgan Lewis’s New York office, where his practice covers a wide range of federal income tax matters with a principal focus on the tax aspects of structured finance transactions. He represents sponsors, managers, and underwriters in collateralized bond, loan, and debt obligation transactions, as well as issuers and underwriters in asset-backed and insurance-related transactions, including credit card, auto loan, marketplace loan, payment plan, and mortgage securitizations. He also brings substantial knowledge of the tax aspects of taxable and tax-free mergers, acquisitions, and dispositions, particularly in the investment management space. His practice areas include Tax, Structured Transactions, and Corporate, Finance & Investment Management, with industry experience in banking.

  • Education & Credentials

Mr. Bogle earned his LL.M. from New York University School of Law in 2002, his J.D. from Columbia University School of Law in 1994, and his B.A. from Loyola College in 1991. He is admitted to practice in New York and New Jersey.

  • Recognition & Leadership

Mr. Bogle was a member of the Morgan Lewis tax practice recognized as a Law360 Practice Group of the Year for Tax in 2017.

  • Professional Involvement

The source does not provide information on bar association memberships or other professional involvement for this section.

  • Experience

Mr. Bogle has more than two decades of experience with the tax considerations relevant to sponsors and managers of investment funds, including hedge funds and private equity funds. He also has a deep background in the tax aspects of various types of financings and in the tax aspects of leveraged ESOP transactions.

 

Justin S. Cohen, Esq., Counsel | Hughes Hubbard & Reed

Justin S. Cohen is a counsel in the New York office of Hughes Hubbard & Reed LLP. He focuses on the tax aspects of domestic and international mergers, acquisitions, and spin-offs, aviation and equipment finance and leasing transactions, corporate finance, securities offerings, and bankruptcy and financial restructurings. He also assists clients with the tax aspects of cross-border investment structuring and private equity and hedge fund formation, and regularly counsels private foundations, country clubs, charitable trusts, and other not-for-profit entities on a variety of compliance issues. His practice areas include Tax, Mergers & Acquisitions, Asset Management, Aviation, Energy & Infrastructure, Venture Capital, Art Law, and the firm’s Not-for-Profit practice.

  • Education & Credentials

Mr. Cohen earned his J.D. from the University of Pennsylvania Law School, where he served as Senior Editor of the University of Pennsylvania Law Review, and also studied at the Wharton School of the University of Pennsylvania. He received his B.S. from Cornell University, magna cum laude. He is admitted to practice in New York and New Jersey.

  • Recognition & Leadership

Mr. Cohen has been recommended in The Legal 500 United States in Tax: US Taxes Non-Contentious each year from 2022 through 2025, and in International Tax in 2024. He received the Presidential Volunteer Service Award and The Legal Aid Society’s Pro Bono Publico Award, both in 2016.

  • Professional Involvement

Mr. Cohen is a member of the New York State Bar Association’s Section of Taxation, where he formerly served as Chair of the Under 10 Club. He has been a speaker at the NYU Tax Conference in 2022, 2023, 2024, and 2025, and co-authored “Avoiding IRS Art Donation Audits Requires an Up-Front Checklist” for Bloomberg Tax in May 2024.

  • Experience

Mr. Cohen’s representative matters include advising Grab in its pending $425 million acquisition of Stash Financial; Cantor Equity Partners II in its business combination with tokenization platform Securitize; Sotheby’s in a $1 billion minority investment round with ADQ; Bloomsbury Publishing in its acquisition of Rowman & Littlefield’s academic imprints; Santander Consumer USA in its $2.5 billion going-private sale; Isos Acquisition Corp. in its $2.6 billion merger with Bowlero; Madison Square Garden Entertainment in the purchase and subsequent sale of Tao Group Hospitality; and multiple SPACs backed by Kensington Capital Partners, including the $3.3 billion QuantumScape merger. He has also represented underwriting groups in ViacomCBS public debt offerings totaling $4.5 billion and advised on aircraft asset-backed securitizations for BBAM Aviation Services and Vx Capital Partners.

 

Sean Austin, Esq_KPMG_FedBarSean Austin, Esq., Managing Director | KPMG

Sean Austin is a Managing Director in the Tax practice at KPMG, where he advises clients on complex partnership taxation, pass-through entities, and transactional tax matters. Based in New York, he works with investment funds, private equity sponsors, and other business enterprises on the federal income tax consequences of partnership formations, operations, restructurings, distributions, and acquisitions. His practice focuses on providing sophisticated tax advice for complex business transactions involving partnerships and other pass-through entities.

  • Education & Credentials

Sean Austin earned his J.D. from New York University School of Law and his B.S. from the Massachusetts Institute of Technology.

  • Recognition & Leadership

Sean is recognized as a leading educator in partnership taxation through his role as faculty for the NYU School of Professional Studies Introduction to Partnerships Taxation program. In that capacity, he has presented on partnership operations, capital accounts, basis adjustments, allocations, and other advanced partnership tax concepts, demonstrating his leadership in tax education and professional development.

  • Professional Involvement

Sean is a frequent speaker on partnership taxation and regularly shares practical insights on the application of Subchapter K to sophisticated business transactions. His involvement in professional education reflects his commitment to helping tax professionals and practitioners navigate complex partnership tax issues.

  • Experience

Before joining KPMG, Sean practiced law at Simpson Thacher & Bartlett, where he advised clients on corporate and tax matters involving mergers and acquisitions, private equity transactions, and business structuring. He now advises investment funds, private equity sponsors, and other business enterprises on the federal income tax consequences of partnership formations, operations, restructurings, distributions, acquisitions, and other transactional tax matters.

 

Charles Kaufman, Esq., Managing Director | KPMG

Charles Kaufman is a Principal in the Passthroughs group of KPMG’s Washington National Tax practice, based in New York. He focuses on transactions involving the taxation of partnerships, real estate investment trusts, and other passthrough entities. He advises private equity funds, tax-exempt entities, and financial institutions on complex investment activities, structured financing, derivatives transactions, and the tax implications of a wide range of private investment vehicles and transactional matters.

  • Education & Credentials

Charles Kaufman holds an LL.M. in Taxation from New York University School of Law, a J.D. from Columbia Law School, and a B.A. in Economics from the City University of New York at Queens College.

  • Recognition & Leadership

Charles serves as a Principal in KPMG’s Washington National Tax Passthroughs group, where he provides technical insight on the federal taxation of partnerships, real estate investment trusts, and S corporations across a broad range of industries. His role as faculty for New York University’s Summer Institute in Taxation also reflects his leadership in partnership tax education.

  • Professional Involvement

Charles serves as faculty for the Introduction to Partnerships Taxation program at New York University’s Summer Institute in Taxation, where he presents the Partnership Operations session. Through his work in KPMG’s Washington National Tax Passthroughs group, he also supports KPMG professionals and clients with technical guidance on the federal taxation of passthrough entities.

  • Experience

Charles has advised clients on numerous real estate transactions, corporate joint ventures, project finance transactions, securitization transactions, partnership restructurings and workouts, and cross-border financings and investments. Prior to joining KPMG, he was a tax associate at Dewey & LeBoeuf LLP, where his practice focused on financial products, cross-border financing transactions, derivatives, capital markets transactions, and corporate transactions.

 

Alan Kravitz, Esq., Partner | Hughes Hubbard & Reed

Alan Kravitz is a partner in the New York office of Hughes Hubbard & Reed LLP, where he focuses his practice on the tax aspects of domestic and international mergers and acquisitions, joint ventures, and structured finance. He has deep experience in aviation finance and equipment finance transactions, in which he has provided tax advice to underwriters, issuers, lenders, and other involved parties. He assists companies and funds with tax matters relating to the acquisition and disposition of subsidiaries and portfolio companies, both domestic and multinational, with a particular focus on the media and technology, telecommunications, and transport and logistics sectors, and advises sponsors on tax considerations relating to the formation and structure of private equity funds.

  • Education & Credentials

Mr. Kravitz earned his J.D. from Columbia University School of Law, where he was a James Kent Scholar and a Harlan Fiske Stone Scholar, and his B.A. from Columbia University. He is admitted to practice in New York and New Jersey.

  • Recognition & Leadership

Mr. Kravitz has been recognized in The Legal 500 in U.S. Tax each year from 2020 through 2025, and in International Tax in 2024.

  • Professional Involvement

Mr. Kravitz is a member of the New York State Bar Association Tax Section’s Corporations Committee and Partnership Committee, and a member of the New York City Bar Association’s Taxation of Business Entities Committee.

  • Experience

Before joining Hughes Hubbard, Mr. Kravitz was a member of the Tax Groups at Clifford Chance and Sullivan & Cromwell, and from 2009 to 2010 served as a law clerk to Judge Mary Ann Cohen of the U.S. Tax Court in Washington, D.C. His representative matters include advising Griffin Global Asset Management on a $1 billion senior unsecured notes offering, a $525 million revolving credit facility, and (with Bain Capital Special Situations) the acquisition of 17 Rolls-Royce engines named the Ishka Global Best European Deal 2023; United Airlines in a $325 million convertible loan to Avianca Holdings named Latin America Deal of the Year by Airfinance Journal; Delta Air Lines in 57 sale-leaseback transactions collectively valued at over $1.5 billion; a 17-bank syndicate in a $5 billion revolving credit facility for Petrobras; Cantor Fitzgerald-backed SPACs in mergers including the $2.1 billion Rumble and $850 million Satellogic transactions; Kensington Capital SPACs including the $1.5 billion Wallbox Chargers merger; and China Minsheng Investment in its approximately $2.2 billion purchase of Sirius International Insurance Group.

 

Ira Aghai, Esq., Associate | Clifford Chance

Ira Aghai is an Associate in Clifford Chance’s Tax team, based in Washington, D.C. He advises clients across a variety of industries on tax and structuring matters related to mergers and acquisitions, restructurings, joint ventures, financings, and private equity and investment fund transactions. Drawing on both private practice and consulting experience, he has developed a strong focus on partnership taxation and complex transactional tax planning.

  • Education & Credentials

Ira Aghai earned his B.A. from the University of Houston in 2009, his J.D. from South Texas College of Law in 2012, and his LL.M. in Taxation from the University of Houston Law Center in 2015. He was admitted as an Attorney-at-Law in Texas in 2013 and in Washington, D.C., in 2022.

  • Recognition & Leadership

Ira serves in leadership roles within several prominent tax organizations, including as Vice Chair of the D.C. Bar Tax Section’s Partnerships and Real Estate Committee and as CLE Chair of the American Bar Association Tax Section’s Partnerships and LLCs Committee. These positions reflect his active leadership within the tax law community.

  • Professional Involvement

In addition to his leadership roles, Ira is an American Bar Association Tax Section contributor. He joined Clifford Chance in 2024, where he continues to advise clients on sophisticated tax and structuring matters while remaining actively engaged in the professional tax community.

  • Experience

Ira’s experience spans both private practice and consulting, with a particular emphasis on partnership taxation. His practice includes advising clients on the tax aspects of mergers and acquisitions,
restructurings, joint ventures, financings, and private equity and investment fund transactions across a broad range of industries.

 

Steven R. Schneider, Esq., Partner | Hogan Lovells

Steven R. Schneider is a nationally recognized tax lawyer and a partner in the Corporate & Finance practice, based in Washington, D.C. He focuses his practice on transactional and tax policy matters primarily in the area of partnerships and limited liability companies. He has significant tax experience across partnerships, real estate, tax equity and credits, energy transition, mergers and acquisitions, private equity and real estate funds, data centers, qualified opportunity zone funds, cross-border tax, REITs, bioscience, international investors including sovereigns, and S corporations.

  • Education & Credentials

Mr. Schneider earned his LL.M. from Georgetown University Law Center, with Distinction, in 1998; his J.D. from Washington University School of Law, Order of the Coif, in 1994; and his B.S. from the University of Missouri, summa cum laude, in 1991. He is admitted to practice in the District of Columbia and before the U.S. Tax Court.

  • Recognition & Leadership

Mr. Schneider was named among Lawdragon’s 500 Leading Global Tax Lawyers in 2025 and recognized as a Key Lawyer for U.S. Taxes: Non-Contentious by The Legal 500 US in 2025. He has been recognized by Best Lawyers in America in Leveraged Buyouts and Private Equity Law (2023–2024) and previously (2013–2021), and by The Legal 500 US in Real Estate Investment Trusts (2020).

  • Professional Involvement

Mr. Schneider is a former Chair of the American Bar Association Tax Section’s Partnerships and LLCs Committee. He has taught a course on drafting partnership and LLC agreements at Georgetown University Law Center since 2005, co-taught a course on energy taxation in 2025, and is a regular speaker at national tax venues with numerous published articles. He presented at the NYU Summer Institute in Taxation’s Introduction to Partnerships Taxation program in July 2025.

  • Experience

Mr. Schneider began his career as a lawyer in the U.S. Internal Revenue Service’s national office and has many years of national-level law firm and Big Four accounting firm experience. His representative matters include advising XPLR Infrastructure (formerly NextEra Energy Partners) on its $1.1 billion divestiture of an interest in the Central Penn Line; Panattoni Development Company on tax matters for multiple development projects and joint ventures; large global real estate funds, developers, and institutional investors on federal income tax matters relating to international and domestic real estate acquisitions, dispositions, and restructurings; and sovereigns and other tax-sensitive investors on real estate and fund investments. He advises on tax equity, energy tax credits, and pass-through entity tax legislative matters, and has represented clients on significant federal tax controversy matters including IRS audits and appeals.

 

Matthew Busta_FedBarMatthew Busta, CPA, Partner | KPMG

Matthew W. Busta, CPA, is a Partner in the Passthroughs group of KPMG’s Washington National Tax practice, based in Philadelphia. He advises partnership clients throughout the firm, with a particular focus on private equity funds, hedge funds, and operating partnerships. His practice includes analyzing complex tax issues arising from partnership transactions, developing sophisticated allocation templates, and preparing technical memoranda and opinions on partnership tax matters.

  • Education & Credentials

Matthew Busta is a Certified Public Accountant (CPA).

  • Recognition & Leadership

Matthew is recognized for his leadership in partnership taxation through his role as faculty for the Introduction to Partnerships Taxation program at New York University’s Summer Institute in Taxation, where he presents the Partner-Partnership Transactions session. He also serves as an editorial advisor for The Tax Adviser and is a former member of the AICPA Partnership Technical Resource Panel.

  • Professional Involvement

Matthew is a frequent instructor for both internal KPMG training programs and client education sessions, and he has authored articles published within KPMG and externally. His continued involvement in professional education and technical publications reflects his commitment to advancing knowledge in partnership taxation.

  • Experience

Before joining KPMG’s Washington National Tax Passthroughs group, Matthew spent more than four years in KPMG’s Business Tax Services practices in Chicago and Minneapolis. He has also played a significant role in the development of KPMG’s passthrough technology, particularly the Asset Management Platform, contributing from its earliest stages by participating in focus groups and providing tax technical guidance throughout its development. Within the Passthroughs group, he advises KPMG professionals and clients on the federal taxation of partnerships, real estate investment trusts, and S corporations across a wide range of industries.

 

Hannah Richard, Esq., Counsel | Clifford Chance

Hannah Richard is Counsel at Clifford Chance, based in New York, where her practice focuses on U.S. federal tax matters involving complex domestic and cross-border transactions. She advises sponsors and investors on fund formation and fund-related matters, including secondary transactions, GP stakes investments, joint ventures, and co-investments. Her practice also includes REIT formation and operations, as well as the tax aspects of mergers and acquisitions and capital markets transactions.

  • Education & Credentials

Hannah Richard earned her B.A. from Birmingham-Southern College in 2007. She was admitted as an Attorney-at-Law in Alabama in 2010 and in New York in 2013.

  • Recognition & Leadership

Hannah advises sponsors and investors on sophisticated domestic and cross-border tax matters, with a practice focused on fund formation, REITs, mergers and acquisitions, and capital markets transactions.

  • Professional Involvement

Hannah joined Clifford Chance in 2014, where she has continued to advise clients on a broad range of complex U.S. federal tax matters involving investment funds, real estate, and corporate transactions.

  • Experience

Hannah’s transactional practice encompasses U.S. federal tax matters arising from complex domestic and cross-border transactions. She has extensive experience advising on fund formation and fund-related matters, including secondary transactions, GP stakes investments, joint ventures, and co-investments, as well as REIT formation and operations and the tax aspects of mergers and acquisitions and capital markets transactions.

 

Olivia Schomburger, Esq., Associate | Clifford Chance

Olivia Schomburger is an Associate in Clifford Chance’s U.S. Tax, Pensions and Employment group in New York. She advises clients on U.S. and international tax matters, with a focus on complex investor-side and sponsor-side structuring and negotiations. Her practice includes advising on the U.S. tax implications of investments by non-U.S. investors, including those subject to special U.S. tax treatment, as well as outbound investments by U.S. taxable and tax-exempt investors.

  • Education & Credentials

Olivia Schomburger earned her B.A. from the University of Arizona in 2013 and her J.D. from Columbia Law School in 2019. She was admitted as an Attorney-at-Law in New York in 2021.

  • Recognition & Leadership

Olivia’s practice focuses on sophisticated U.S. and international tax matters involving complex investor-side and sponsor-side transactions, advising institutional investors and investment sponsors on domestic and cross-border tax structuring and negotiations.

  • Professional Involvement

Olivia joined Clifford Chance in 2025, where she advises clients on a broad range of U.S. and international tax matters involving private equity, hedge funds, fund-of-funds, and other investment structures.

  • Experience

Olivia advises global institutional investors on primary and secondary GP-led transactions, including continuation fund structures for single- and multi-asset deals. Her experience includes negotiating and reviewing transaction documents and tax disclosures for mergers and acquisitions, REIT sales, credit agreements, and other corporate transactions; negotiating and drafting side letter provisions and diligence confirmations for complex investor groups; and preparing tax disclosures and investment documentation for hedge fund, private equity, and fund-of-funds clients. Prior to joining Clifford Chance, she advised BlackRock on its $12.5 billion acquisition of Global Infrastructure Partners and Goldman Sachs on its sale of Aviation Facilities Company Management (AFCO) to Ardian Infrastructure.

 

FedBar Logo_FedBarAnnet M. Thomas-Pett, CPA, Managing Director | PwC

Annet Thomas-Pett is a Managing Director in PwC’s National Real Estate Tax Practice, based in New York. She has over 17 years of experience working with real estate advisors, private equity real estate fund sponsors, both public and private REITs, and high-net-worth individuals. She has extensive real estate experience and is considered a technical expert in federal taxation, particularly in the real estate area.

  • Education & Credentials

Ms. Thomas-Pett received a Bachelor of Science in accounting and a Master of Science in taxation, graduating summa cum laude, from St. John’s University. She is a certified public accountant in New York.

  • Recognition & Leadership

Ms. Thomas-Pett is Vice Chair of the Real Estate Tax Committee of the American Bar Association.

  • Professional Involvement

Ms. Thomas-Pett has published a number of articles on real estate topics in Taxes – The Tax Magazine, the Journal of Passthrough Entities, and Real Estate Taxation. She regularly speaks at real estate tax conferences sponsored by organizations including the American Bar Association, the Los Angeles County Bar Association, and NAREIT.

  • Experience

Ms. Thomas-Pett has worked on a variety of real estate transactions over her career, including REIT due diligence and tax opinions, REIT M&A transactions, FIRPTA planning and structuring, Section 1031 exchanges, and global private equity real estate fund and deal structuring.

Agenda

DAY 1, MONDAY, JULY 27, 2026

 

WELCOME REMARKS | 8:25am – 8:30am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

SESSION 1 – INTRODUCTION, CHOICE OF ENTITY AND FORMATION | 8:30am – 12:00pm

Introduction; choice of entity considerations; entity classification and restrictions on partnership status. Formation of a partnership nonrecognition, beginning book and tax capital account and beginning basis; taxable year; methods of accounting.

Charles R. Bogle, Esq., Partner, Morgan, Lewis & Bockius, New York, NY
Justin S. Cohen, Esq., Counsel, Hughes Hubbard & Reed, New York, NY

 

BREAK | 10:00am – 10:15am

LUNCH | 12:00pm – 1:00pm

 

SESSION 2 – PARTNERSHIP OPERATIONS | 1:00pm – 4:30pm

Effect of partnership operations on tax and book capital accounts and basis; special allocations.

Sean Austin, Esq., Managing Director, KPMG, New York, NY
Charles Kaufman, Esq., Managing Director, KPMG, New York, NY

 

BREAK | 2:30pm – 2:45pm

 

DAY 2, TUESDAY, JULY 28, 2026

 

SESSION 1 – NONRECOURSE ALLOCATIONS | 8:30am – 11:45am

Allocations of nonrecourse debt and nonrecourse deductions.

Alan Kravitz, Esq., Partner, Hughes Hubbard & Reed, New York, NY
Ira Aghai, Esq., Associate, Clifford Chance, Washington, DC

 

BREAK | 10:00am – 10:15am

LUNCH | 11:45am – 12:45pm

 

SESSION 2 – PARTNERSHIP DISTRIBUTIONS | 12:45pm – 2:00pm

Current and liquidating distributions, disproportionate distributions.

Alan Kravitz, Esq., Partner, Hughes Hubbard & Reed, New York, NY
Ira Aghai, Esq., Associate, Clifford Chance, Washington, DC

 

BREAK | 2:00pm – 2:15pm

 

SESSION 3 – PARTNER-PARTNERSHIP TRANSACTIONS | 2:15pm – 4:30pm

Disguised sales and other partner-partnership transactions.

Steven R. Schneider, Esq., Partner, Hogan Lovells, Washington, DC
Matthew Busta, CPA, Partner, KPMG, Philadelphia, PA

 

DAY 3, WEDNESDAY, JULY 29, 2026

 

SESSION 1 – TRANSFERS OF PARTNERSHIP INTERESTS | 8:30am – 10:00am

Sales and purchases of partnership interests.

Hannah Richard, Esq., Counsel, Clifford Chance New York, NY
Olivia Schomburger, Esq., Associate, Clifford Chance, New York, NY

 

BREAK | 10:00am – 10:15am

 

SESSION 2 – RETIREMENT AND DEATH OF A PARTNER| 10:15am – 12:00pm

Consequences under subchapter K, including effect on timing and character of income.

Hannah Richard, Esq., Counsel, Clifford Chance New York, NY
Olivia Schomburger, Esq., Associate, Clifford Chance, New York, NY

 

LUNCH | 12:00pm – 1:00pm

 

SESSION 3 – HOT TOPICS | 1:00pm – 2:00pm

An overview of recent developments in the law and in the uses of partnerships.

James A. Gouwar, Esq., Partner, Sidley Austin, New York, NY
Annet M. Thomas-Pett, CPA, Managing Director, PwC, New York, NY

 

BREAK | 2:00pm – 2:15pm

 

SESSION 4 – THE TROUBLED PARTNERSHIP | 2:15pm – 3:30pm

Workouts; foreclosure; deed in lieu; abandonment of partnership interest.

James A. Gouwar, Esq., Partner, Clifford Chance, New York, NY
Annet M. Thomas-Pett, CPA, Managing Director, PwC, New York, NY

SESSION 5 – SUMMING UP | 3:30pm – 4:30pm

Work through a partnership tax return and a sample partnership agreement with emphasis on the tax-sensitive provisions, such as capital account maintenance, book-ups, choice of allocation methods under Section 704(c), allocation and distribution provisions, and liquidation provisions.

James A. Gouwar, Esq., Partner, Sidley Austin, New York, NY
Annet M. Thomas-Pett, CPA, Managing Director, PwC, New York, NY

Credits

Alaska

Approved for CLE Credits
19.58 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for Self-Study Credits
19.6 General

Arkansas

Approved for CLE Credits
19.58 General

Arizona

Approved for CLE Credits
19.58 General

California

Approved for CLE Credits
19.58 General

Colorado

Pending CLE Approval
19.58 General

Connecticut

Approved for CLE Credits
19.58 General

District of Columbia

No MCLE Required
No MCLE Required

Delaware

Pending CLE Approval
19.58 General

Florida

Approved via Attorney Submission
19.5 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Pending CLE Approval
19.58 General

Hawaii

Approved for CLE Credits
19.58 General

Iowa

Pending CLE Approval
19.58 General

Idaho

Pending CLE Approval
19.58 General

Illinois

Pending CLE Approval
19.58 General

Indiana

Pending CLE Approval
19.58 General

Kansas

Pending CLE Approval
19.58 Substantive

Kentucky

Pending CLE Approval
19.58 General

Louisiana

Pending CLE Approval
19.58 General

Massachusetts

No MCLE Required
19.58 CLE Hour(s)

Maryland

No MCLE Required
19.58 CLE Hour(s)

Maine

Pending CLE Approval
19.58 General

Michigan

No MCLE Required
19.58 CLE Hour(s)

Minnesota

Pending CLE Approval
19.58 General

Missouri

Approved for Self-Study Credits
23.5 General

Mississippi

Pending CLE Approval
19.58 General

Montana

Pending CLE Approval
19.58 General

North Carolina

Pending CLE Approval
19.58 General

North Dakota

Approved for CLE Credits
19.58 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
15 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
1174.8 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
23.5 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
19.58 General

Nevada

Pending CLE Approval
19.58 General

New York

Approved for CLE Credits
23 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for Self-Study Credits
19.5 General

Oklahoma

Pending CLE Approval
23.5 General

Oregon

Pending CLE Approval
19.58 General

Pennsylvania

Approved for Self-Study Credits
20 General

Rhode Island

Pending CLE Approval
23.5 General

South Carolina

Pending CLE Approval
19.58 General

South Dakota

No MCLE Required
19.58 CLE Hour(s)

Tennessee

Approved for Self-Study Credits
19.58 General

Texas

Approved for CLE Credits
19.58 General

Utah

Pending CLE Approval
19.58 General

Virginia

Not Eligible
19.58 General Hours

Vermont

Approved for CLE Credits
19.58 General

Washington

Approved via Attorney Submission
19.58 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Approved for Self-Study Credits
23.5 General

West Virginia

Pending CLE Approval
23.5 General

Wyoming

Pending CLE Approval
19.58 General

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