Castle Harbour Decision: Legitimacy of Partnerships With Tax Benefits
Structuring the Entity to Withstand IRS Scrutiny and Maximize Tax Advantages
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE course will analyze the recent ruling in the Castle Harbour case, its impact on determining the legitimacy of partnership structures with tax benefits, and best practices for structuring partnerships to withstand IRS scrutiny.
Outline
- Analysis of court’s ruling
- Family partnership status under section 704(e)
- Partnership status test under Culbertson
- Impact of ruling on future IRS challenges to legitimacy of partnerships
- Structuring partnerships to withstand IRS attack
Benefits
The panel will review these and other key questions:
- How will the Castle Harbour ruling impact the way courts view the legitimacy of partnership structures with tax benefits?
- Will this decision impact future IRS challenges of partnership structures with tax benefits?
- What proactive steps should counsel take on behalf of current and prospective clients in light of the Castle Harbour ruling?
Faculty
Lawrence M. Hill
Partner
Dewey & LeBoeuf
He is lead litigation counsel to a major international bank in civil litigation and government investigations involving... | Read More
He is lead litigation counsel to a major international bank in civil litigation and government investigations involving alleged tax shelters. He is also lead counsel to major professional services firms and financial institutions under promoter penalty investigation by the IRS, and has represented clients in tax shelter investigations conducted by the U.S. Senate Finance Committee.
CloseTodd Y. McArthur
Partner
Dewey & LeBoeuf
He represents multinational corporations and private investors in a wide range of transactions, including transactions... | Read More
He represents multinational corporations and private investors in a wide range of transactions, including transactions dealing with domestic and cross-border partnerships, strategic joint ventures, and other partnership acquisitions, dispositions and restructurings. He has extensive tax controversy experience that is generally centered on leasing and partnership tax matters.
CloseAbraham N. M. Shashy
Partner
Dewey & LeBoeuf
His practice includes transactional tax planning for, and tax controversy representation of, multinational corporations... | Read More
His practice includes transactional tax planning for, and tax controversy representation of, multinational corporations in a variety of domestic and international contexts including partnerships and joint ventures, capital market and finance transactions, business combinations and reorganizations, mergers and acquisitions. He served as Chief Counsel for the IRS from February 1990 to January 1993.
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