Structuring Contributions of Appreciated Property to Partnerships: Avoiding Tax Recognition on Built-In Gain Assets
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel with a comprehensive guide to the tax consequences of contributing appreciated property to a partnership or multi-member LLC. The panel will discuss the specific tax treatment of appreciated property's contribution with debt, depreciation allocation, both liquidating and nonliquidating distributions, and capital account adjustments and allocations.
Outline
- General nonrecognition rules
- Current tax consequences for the contribution of appreciated property with debt encumbrance
- Basis adjustments required by the partnership
- Impact of distributions to contributing partner
- Impact of recently proposed tax law changes
Benefits
The panel will discuss these and other important topics:
- Under what circumstances would contribution of appreciated property not qualify for nonrecognition under Section 721?
- What is the "seven-year rule" of Section 737, and how does it impact distributions to partners who have previously contributed appreciated property?
- What is the impact on the contributing partner when the partnership distributes the appreciated property to other partners?
- What impact would the recently proposed tax law changes have on these rules?
Faculty
Joseph C. Mandarino
Partner
Smith Gambrell & Russell
Mandarino is a Partner in the Tax Practice of Smith, Gambrell & Russell, LLP. His practice focuses on... | Read More
Mandarino is a Partner in the Tax Practice of Smith, Gambrell & Russell, LLP. His practice focuses on corporate, tax and finance law. Mr. Mandarino is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino writes and speaks extensively on a wide range of business, tax and finance topics.
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Kate L. Mathieu
Attorney
Skadden Arps Slate Meagher & Flom
Ms. Mathieu advises public and private companies on a broad range of U.S. federal income tax matters, with a particular... | Read More
Ms. Mathieu advises public and private companies on a broad range of U.S. federal income tax matters, with a particular focus on both domestic and international transactions. Ms. Mathieu’s practice includes significant work involving the tax aspects of corporate mergers and acquisitions, spin-offs, and partnership transactions. She also advises clients with regard to the taxation of debt and equity financings, initial public offerings, and internal integration and restructuring transactions.
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Paul Schockett
Partner
Skadden Arps Slate Meagher & Flom
Mr. Schockett advises public and private companies on a broad range of U.S. federal income tax matters, with... | Read More
Mr. Schockett advises public and private companies on a broad range of U.S. federal income tax matters, with particular focus on U.S. and cross-border transactions. His practice includes significant work involving the tax aspects of partnership acquisitions and dispositions, joint venture and investment fund formations, and corporate mergers and acquisitions. He also advises clients with regard to the taxation of debt and equity financings, initial public offerings, bankruptcy restructurings and internal reorganizations. He frequently writes and lectures on tax-related topics, including partnership taxation, M&A transaction structuring, tax aspects of troubled company workouts, and renewable energy tax benefits.
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