IRC 751 "Hot Asset" Treatment: New Rules for Calculating Ordinary Income Recharacterization
New IRS Proposal on Determining Partners' Share of Section 751 Ownership
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel with a practical and thorough guide to structuring partnership distributions of Section 751 “hot assets,” such as inventory and unrealized receivables. The panel will discuss the default “distribution as exchange” rule and offer details on the substantive changes in treatment outlined in recently proposed regulations to overhaul how Section 751(b) is applied to distributions of partnership ordinary income assets.
- Section 751 provisions
- 751(a) ordinary income recharacterization provisions
- 752(b) listed assets
- Substantially appreciated inventory
- Current rules for calculating ordinary income recharacterization
- Proposed regulations’ approach to calculating ordinary income from Section 751 property
The panel will review these and other key issues:
- How will the proposed regulations affect tax treatment of sales and/or distributions for partners holding ownership interests in partnerships holding Section 751 assets?
- What industries will be most affected by the proposed change to Section 751 property calculations?
- How does the new approach change allocation of partnership assets?
- What steps must tax counsel take for partnership clients to utilize potential tax advantages of the proposed regulations?
Jennifer A. O'Leary
Ms. O'Leary is a partner in her firm's Tax Practice Group. She focuses her practice on the federal income... | Read More
Ms. O'Leary is a partner in her firm's Tax Practice Group. She focuses her practice on the federal income tax aspects of pass-throughs, private investment funds, domestic and international mergers and acquisitions, dispositions, corporate tax restructuring, debt restructuring, regulated investment companies and real estate investments trusts.Close
Morgan L. Klinzing
Ms. Klinzing focuses her practice on the federal income tax aspects of U.S and international mergers and acquisitions.... | Read More
Ms. Klinzing focuses her practice on the federal income tax aspects of U.S and international mergers and acquisitions. Her experience includes advising clients on partnership formation, operations and exit issues. She works with private equity funds to coordinate cross-border tax advice for structuring investments in a tax efficient manner. In addition, she counsels clients operating as partnerships, limited liability companies and S corporations on characterization of gain in an exit.Close