Partnership Distributions: Avoiding Tax Traps of Mixing Bowl Transactions, Disguised Sales, and 751(b)
Gaining Insight Into the Complex Tax Concepts Through Real World Examples
Recording of a 110-minute CPE webinar with Q&A
This teleconference will provide tax professionals with an in-depth review of the rules for disguised sales, mixing-bowl transactions and partnership distribution transactions under Sect. 751(b). The panel will also address how to avoid negative tax consequences.
Outline
- Analysis of applicable IRC sections
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Transactions likely to be problematic or permissible for tax purposes
- Disguised sales
- Mixing-bowl transactions
- Best practices
Benefits
The panel will review will review topics including:
- Best practices for handling pitfalls in Sect. 751(b).
- Transactions most likely to trigger disguised sale and anti-abuse rules — and result in taxable events.
- When transactions are deemed mixing-bowl transactions.
- Requirements for Sect. 751(b) to apply.
- Common business considerations in mixing-bowl transactions.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
David Blair
Partner
Crowell & Moring
Mr. Blair practice is in the area of federal tax litigation and controversy. He has more than 20 years of tax... | Read More
Mr. Blair practice is in the area of federal tax litigation and controversy. He has more than 20 years of tax litigation and trial experience and has handled large tax litigation in the areas of transfer pricing, foreign tax credits, partnerships, tax-exempt bonds, consolidated returns, excise taxes, employment taxes, and tax accounting issues.
CloseThomas I. Hausman
Schneider Smeltz Ranney & LaFond
Mr. Hausman specializes in tax, partnership and corporate practice, and estate planning. He counsels clients on,... | Read More
Mr. Hausman specializes in tax, partnership and corporate practice, and estate planning. He counsels clients on, and prepares, partnership agreements, shareholders’ agreements, succession planning agreements, wills, trusts, merger and business acquisition agreements, like-kind exchanges, and employment contracts. He has taught tax law at Case Western Reserve University School of Law since 1992.
CloseBruce Belman
Partner
Crowe Horwath
Mr. Belman has over 35 years of experience as a tax planning specialist focusing on partnership and LLC taxation,... | Read More
Mr. Belman has over 35 years of experience as a tax planning specialist focusing on partnership and LLC taxation, individual taxation, Subchapter “S” taxation and estate planning. His primary industry focus has been real estate. Mr. Belman has also worked with clients in the food and commodity sector and has assisted private equity groups with acquisition structuring, buy side due diligence and in serving portfolio companies post-transaction. He frequently writes, teaches, and speaks on topics within the scope of his expertise.
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