Description
Gain insight into the issues presented when you are involved in the construction, structuring, andor reporting of ownership transactions.IRC Sec. 751 contains some of the more difficult rules to navigate in Subchapter K, and have potential implications with every partnershipLLC ownership transaction. The aggressive bonus depreciation rules of recent years increase the potential for Sec. 751 implications. Likewise, the proliferation of disproportionate allocation structures and the use of different classes of ownership interests increases the complexities inherent in trying to apply Sec. 751 to actual transactions. This topic will give you the information you need to be conversant in the issues presented when you are involved in the construction, structuring, andor reporting of ownership transactions.
Date: 2020-03-06 Start Time: End Time:
Learning Objectives
What Is Sec. 751 and When Does It Come Into Play?
• Overview and History of Sec. 751 Under the Aggregate Theory of Taxation
• Sec. 751(a) • Transfer of Partnership Interest
• Sec. 751(b) • Distribution of Partnership Property
• Hot Assets
• Unrealized Receivables
• Inventory
• Substantially Appreciate Inventory
Review of the Sec. 751 Regulations and Other Authorities
• Overview of Existing Regulations
• Overview of 2014 Proposed Regulations
• Discussion of Primary Areas for Which Guidance Remains Lacking
Illustrate the Application of Sec. 751 in the Context of Typical Transactions
• Potential Structure Considerations and Alternatives
• Buyer and Seller Negotiating Points
• Form 8308 and Other Reporting Requirements
• Potential Sec. 751 Impact on a Sec. 736 Transaction
CPE ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Joseph Schlueter-Baker Tilly Virchow Krause, LLP
