Pass-Through Liabilities and Federal Tax Treatment: Resolving Complex Issues
Properly Characterizing Liabilities for GPs, LPs and LLCs Given Inconsistencies in the Tax Code
Recording of a 110-minute CLE teleconference with Q&A
Conducted on Wednesday, August 29, 2012
Recorded event now available
This teleconference will provide advisors and corporate taxpayers using pass-through entities in their business structures a review of how certain Code sections dictate handling of liabilities. The panel will share experiences on how liabilities should be treated in scenarios commonly faced by businesses.
Description
In the current economy, many taxpayers have used partnership liabilities to create tax basis and at-risk basis to claim losses—or have created income from discharging indebtedness for which a Section 108 exclusion is possible. Yet, inconsistencies in how federal tax laws characterize liabilities create problems.
It can be confusing to determine whether certain Code sections treat a liability as recourse or non-recourse. There is no clear guidance about handling liabilities when a partnership converts to a disregarded entity, or vice versa. Taxpayers are groping for clear direction on pass-through liabilities.
In seeking answers on proper treatment of liabilities, taxpayers and advisors must navigate several parts of the Code (including sections 752, 1001, 465 and 704, to name some) and still get conflicting or differing answers.
Listen as our panel of seasoned tax advisors uses various general partnership, limited partnership and LLC scenarios to provide a framework for making well founded decisions about proper treatment of liabilities.
Outline
- Frequent sources of conflict with IRC treatment of pass-through liabilities
- Liability characterization under Section 1001
- Liability characterization under Section 752
- Recourse liabilities under Section 752
- Non-recourse liabilities under Section 752
- Liability characterization with Section 704(b)
- Frequently faced fact patterns with federal tax treatment of pass-through liabilities
- Inter-woven issues with state law
Benefits
The panel will analyze situations involving these and other important issues:
- Treating liabilities as recourse or non-recourse under different purposes and Code sections.
- Handling cancellation of indebtedness income for pass-through entities.
- Resolving liability concerns during conversions with disregarded entities.
Upon completing this seminar, you will be better prepared to make informed decisions about proper federal tax treatment of pass-through liabilities, given the different treatment afforded by different sections of the Internal Revenue Code.
Faculty
Carolyn Turnbull, Tax Director
McGladrey, Orlando, Fla.
She works routinely with the firm's clients on engagements involving pass-through entities, and has extensive experience on a range of other complex corporate federal and state tax engagements. Before coming to McGladrey, she was director of tax for the Moore Stephens Tiller accounting firm.
Belan Wagner, Managing Partner
Wagner Kirkman Blaine Klomparens & Youmans, Mather, Calif.
He has 35 years of professional experience and works on tax and business planning matters, among numerous other engagements. He provides direct representation to business owner clients, frequently structured as pass-through entities, and also acts as an expert resource to their primary attorneys, accountants and other representatives.
Ordering
Online Seminar - Audio Recording
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Online Seminar Audio $247.00
Available 24 hours after the live event
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Available ten business days after the live event
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Customer Reviews
Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.
Rhonda G. Williams, CPA
Barraclough & Associates
The conference was technical, informative and presented at a good pace.
Krystal Ching
KMH
I purchased the conference a few minutes after it began and the customer service rep was very helpful and got me signed up and logged into the conference very quickly.
Joanna Johnston
Savas Greene & Company
I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.
Matt Bristow
Cover & Rossiter
I appreciated the flow of the information offered and the ease at which I could follow the handouts.
Larry Bruck
WISS & Company
Federal Tax Accounting Advisory Board
David Bowen
Principal
Grant Thornton
Joseph Calianno
Partner, National Tax Practice
Grant Thornton
Of Counsel
Morrison & Foerster
Shareholder
Roth & Co. CPAs
George Manousos
Partner
PricewaterhouseCoopers
Federal Tax Partner
Nixon Peabody
Partner
Ivins, Phillips & Barker
Of Counsel
Skadden Arps
Tom Windram
Managing Director & National Leader, Federal Tax Credits & Incentives
RSM McGladrey
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