Partnership Basis and Distributions: Navigating Sections 731-737, 751(b) and 755
Recording of a 110-minute CPE/CLE webinar with Q&A
This webinar will provide tax advisors and managers with an in-depth review of the rules for partnership basis adjustments and distributions under Internal Revenue Code Sections 731 through 737, 751(b) and 755.
Outline
- Three basic types of distributions resulting from a partnership
- Non-liquidating distributions of cash and other property
- Liquidating distributions of cash and other property that eliminate a partner's interest
- Disproportionate distributions that affect partner's share of ordinary income
- Sect. 731 on gain or loss recognition
- Sect. 732 on partner's basis of property received
- Money
- Other property
- Sect. 733 on partner's remaining basis
- Sect. 734 on adjustment to basis
- Sect. 751(b)
- Purpose
- Disproportionate distribution occurrences
- Hot assets include unrealized receivables and substantially appreciated inventory
- Other property, including cash
- Disproportionate distribution occurrences
- Circumstances under which Sect. 751 does and does not apply
- Purpose
- Sect. 755
- Best practices for partnership distributions
- Special problems
- Mixing bowl transactions
- Enactment of Sect. 737
- Two special adjustment rules
Benefits
The panel will explore topics such as:
- Determining when basis of property received exceeds the partnership interest's outside basis.
- Pinpointing the circumstances under which utilizing Sect. 732 makes the most sense.
- Identifying and handling potential pitfalls in Sect. 751(b).
- Understanding practical issues with special basis adjustments under Sect. 755 caused by installment sales and modified depreciation on stepped-up assets.
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.
Close
Lynn E. Fowler
Partner
Kilpatrick Townsend & Stockton
Mr. Fowler's practice specializes in tax-efficient strategies for a variety of business entity formation,... | Read More
Mr. Fowler's practice specializes in tax-efficient strategies for a variety of business entity formation, financing, operations and disposition transactions. He has worked with clients frequently on federal income tax credits, and taxable and tax-free M&A transactions.
Close