IRC Section 707 Transactions Between Partnerships and Their Members
Navigating Disguised Sales Provisions and Avoiding Other Pitfalls Under Anti-Abuse Rules
Recording of a 110-minute CLE/CPE webinar with Q&A
This teleconference will provide tax counsel with a guide to the impact of IRC Section 707 on business transactions between partnerships and partners. The panel will explore the analyses used by the IRS and courts to deem business deals as disguised sales and abusive situations triggering taxable events.
- Analysis of IRC Section 707
- Section 707(a)(2): partner vs non-partner capacity
- Section 707(a)(2)(A): partner performance of services
- Section 707(a)(2)(B): partner transfers of property
- Section 707(b)(1): disallowance of losses
- Section 707(b)(2): treatment of gains as ordinary income
- Section 707(b)(3): ownership of a capital or profits interest
- Section 707(b)(3)(c): guaranteed payments
- Administrative Guidance and Decisions Involving Section 707
- Canal Corp. v. Commissioner, U.S. Tax Court
- IRS Anti-Abuse Regulations
- II(c) Virginia Historic Tax Credit Fund 2001 LP vs. Commissioner, 4th Circuit
- Section 707 Planning Issues
- Business structures under audit
- Transactions that are likely to be problematic or permissible for tax purposes
The panel will review these and other key questions:
- How do the provisions of Section 707 distinguish between partnership-partner transactions that are taxable events and those that are not?
- What kinds of transactions are the most likely to trigger disguised sale and anti-abuse rules, resulting in taxable events?
- What business structures are the IRS scrutinizing in connection with Section 707?
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
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
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