IRC 751 "Hot Assets": Calculating and Reporting Ordinary Income in Disposition of Partnership or LLC Interests
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide accounting and tax professionals with a deep dive into the tax treatment of so-called Section 751 “hot assets” when a partner disposes of his or her partnership interest. The panel will discuss identifying, calculating and reporting of ordinary income from hot assets in the sale of a partnership or LLC interest, and will review the proposed regulations under Section 751(b).
- Section 751(a) asset rules
- Section 752(b) listed assets
- Unrealized receivables
- Substantially appreciated inventory
- Proposed regulations under Section 751
The panel will discuss these and other important issues:
- How does the regime of Section 751 work in calculating gain/loss from ordinary income producing assets held at the partnership level?
- What assets does Section 751 require to be calculated separately?
- How are inventory assets treated differently in a redemption vs. a sale of partnership interest?
- What options are available regarding cost allocation to minimize gain calculations on Section 751 assets?
- What are the potential effects of the proposed regulations under Section 751(b)?
Smith Gambrell & Russell
With more than two decades of experience in tax law both in the United States and in Israel, Mr. Keinan focuses on U.S.... | Read More
With more than two decades of experience in tax law both in the United States and in Israel, Mr. Keinan focuses on U.S. and international taxation of financial products and institutions and represents multinational entities, banks, hedge funds, private equity funds and REITs. He has a broad tax practice, which also includes representing high net-worth individuals and providing support to entities and individuals involved in IRS disputes. Prior to joining his Firm, he headed Carter Ledyard & Milburn’s Tax Practice in New York, served as shareholder at Greenberg Traurig’s Tax and International Tax Practices in New York, as senior manager with Ernst & Young’s National Tax Department in Washington, D.C., as an associate with Shearman & Sterling’s Tax Practice in Washington, DC., and as a Manager with Ernst & Young’s tax department in Israel.Close
James Lynch, Esq., CPA
Sobel & Co.
Mr. Lynch is the Firm's Tax Director and is charged with preparing many of the Firm's more complex... | Read More
Mr. Lynch is the Firm's Tax Director and is charged with preparing many of the Firm's more complex personal, partnership, and fiduciary returns, as well as most of the firm's estate tax returns. In addition, he is significantly involved in research and planning, particularly in the partnership and estate areas.Close
Brian Keida, CPA
Tax Senior Manager
With more than thirteen years of public accounting experience, Mr. Keida’s industry focus has been serving... | Read More
With more than thirteen years of public accounting experience, Mr. Keida’s industry focus has been serving clients predominantly in the real estate and asset management industry. The clients primarily have been investment funds, real estate companies, home builders and developers, REIT’s, private equity and sovereign wealth funds. His technical focus is in the areas of partnership compliance and structuring with diverse investor profiles, revenue recognition for home builders, in-bound foreign investment in US real estate, REIT and corporate taxation.Close
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