New IRS Partnership Transfer Rules for Contributions of Appreciated Property to Partnerships With Foreign Partners
Understanding Impact of IRS Notice 2015-54 and Preserving Nonrecognition Treatment
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel with an exploration into the ramifications of IRS Notice 2015-54, released Aug. 6, 2015, which will generally make a taxable event of any contribution of appreciated property by a U.S. person to a related partnership, unless strict requirements are satisfied. The panel will review the current rules, describe the changes — the most important of which are already in effect — and discuss tools to work around the recognition requirement.
Outline
- Current rules on contributions to foreign partnerships
- Notice 2015-54 rule changes requiring recognition of gain on contribution of appreciated property
- How to defer gain recognition
- Effect on IRS authority to make adjustments under Section 482
Benefits
The panel will discuss these and other critical questions:
- What are the technical terms and mechanics of the new regulations?
- What effect will the new regulations have on existing partnership arrangements?
- What are the requirements for the gain deferral method?
Faculty
L. Andrew Immerman
Partner
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.
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Matthew P. Moseley
Alston & Bird
Mr. Moseley's pracitce focuses on the U.S. federal income tax consequences of domestic and cross-border... | Read More
Mr. Moseley's pracitce focuses on the U.S. federal income tax consequences of domestic and cross-border business transactions. He is experienced in international transfer pricing matters, including the transfer of intellectual property, structuring the acquisition or disposition of U.S. or foreign business entities, planning international reorganizations, and determining the applicability of U.S. tax treaties. He has prepared and negotiated cost-sharing agreements, assisted clients in obtaining advanced pricing agreements and guided clients through the process of seeking competent authority relief.
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Heather Ripley
Alston & Bird
Ms. Ripley's practice focuses on federal and international tax services for a range of clients, including... | Read More
Ms. Ripley's practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals. She advises clients on income tax treaty application, FATCA, FIRPTA and other tax issues for inbound investment into the United States, the anti-deferral regimes for outbound investment and tax-efficient transactions and structures. She also navigates clients through the IRS’s ongoing Offshore Voluntary Disclosure Program and corresponding state disclosure programs.
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