IRC 751 "Hot Assets": Calculating and Reporting Ordinary Income on 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)?
Morgan L. Klinzing
Troutman Pepper Hamilton Sanders
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
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.Close