New Partnership Debt Allocation Regulations: Applying Risk of Loss Analysis to IRC 707 Disguised Sale Rules
Restoring Use of Leveraged Partnerships and Asset Drop-Down Transactions, Preserving Deferral Treatment
This program is postponed. New date TBD.
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers with a practical guide to the new proposed IRS guidance on partnership recourse debt allocation. The proposed regs largely undo the controversial 2016 rules governing the allocation of partnership liabilities and partnership “disguised sales.” The panel will discuss the new regulations within the context of the TCJA provisions limiting interest expense deduction, and detail the additional deferral opportunities using “leveraged partnerships.”
- 2016 temporary and proposed regulations and impact on leveraged partnerships and asset drop-down transactions
- Section 707 disguised sale rules
- Distinguishing recourse from nonrecourse debt
- New proposed regulations reversing the 2016 rules
- Applying the “economic risk of loss” analysis to the allocation of partnership debt for purposes of Section 707
- Retention of 2016 rules restricting “bottom dollar payment obligations”
- Restoring planning opportunities with leveraged partnerships
This panel will help practitioners navigate the challenges posed by the new regulations by discussing these and other important topics:
- Distinguishing recourse from nonrecourse partnership debt
- The impact of the new regulations on everyday business transactions, such as leveraged partnerships and asset drop-down transactions
- Allocating debt based on the economic risk of loss to contributing partner
- What parts of the 2016 rules do the new proposed regulations reverse, and which parts do they keep?
Wick Phillips Gould & Martin
Ms. Blair advises clients on federal income tax and Texas state tax planning applicable to partnerships, limited... | Read More
Ms. Blair advises clients on federal income tax and Texas state tax planning applicable to partnerships, limited liability companies, S corporations, and privately and publicly held corporations. Her experience includes the formation, operation and dissolution of closely held corporations, partnerships, limited liability companies and S corporations. She has also advised clients regarding federal income tax planning for various business entities, including counsel on tax aspects of taxable and tax-free mergers, acquisitions, reorganizations and dispositions, equity and debt offerings and real estate transactions; she has particular experience in the areas of partnership and oil and gas taxation.Close
to be announced.
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