IRC Sect. 707: Transactions Between Partner and Partnership
Navigating Disguised Sales Provisions and Avoiding Other Pitfalls Under Anti-Abuse Rules
Recording of a 110-minute CPE/CLE webinar with Q&A
This teleconference will provide tax advisors with a review of the key tax ramifications involved with transactions between partners and partnerships under Sect. 707 of the Internal Revenue Code.
- Important provisions of Sect. 707
- Sect. 707(a)(2)(A) on partner performance of services
- Sect. 707(a)(2)(B) on partner transfers of property
- Sect. 707(b)(1) on disallowance of losses
- Sect. 707(b)(2) on treatment of gains as ordinary income
- Sect. 707(b)(3) on ownership of a capital or profits interest
- Sect. 707(b)(3)(c) on guaranteed payments
- Administrative guidance and decisions involving Sect. 707
- Relevant IRS private letter rulings and written determinations
- Canal Corp. v. Commissioner, U.S. Tax Court
- Leveraged partnership transaction triggered anti-abuse rules
- Current IRS audit policy
- Partner-partnership structures currently under audit
- Lessons for other taxpayers and advisors
- Transactions that seem problematic, permissible going forward from a tax standpoint
The panel will analyze and tackle these and other relevant topics:
- Critically important terms of Sect. 707, related administrative guidance and court rulings.
- Transactions that are most likely to run afoul of the disguised sale and anti-abuse rules, and those likely to avoid a taxability declaration.
- The kinds of structures currently attracting attention in IRS audits, and the implications for other taxpayers and advisors.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
L. Andrew Immerman
Alston & Bird
Mr. Immerman concentrates on federal income tax matters, including domestic and international tax planning and... | Read More
Mr. Immerman concentrates on federal income tax matters, including domestic and international tax planning and transactional work for joint ventures, partnerships, limited liability companies and corporations. He has helped structure many sophisticated partnership and limited liability company transactions and has represented the target or the acquirer in numerous corporate mergers and acquisitions.Close
Carruthers & Roth
He works with business clients on a wide range of tax and succession planning, compensation and management structure... | Read More
He works with business clients on a wide range of tax and succession planning, compensation and management structure issues. He has written and spoken frequently on Sect. 707-related topics.Close
Baker & McKenzie
She works on tax issues for corporations and partnerships, LLCs and other pass-through entities. She speaks frequently... | Read More
She works on tax issues for corporations and partnerships, LLCs and other pass-through entities. She speaks frequently on partnership tax matters.Close