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


Conducted on Wednesday, September 18, 2013

Recorded event now available

or call 1-800-926-7926
Program Materials

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.

Description

Sect. 751(b) transactions are deceptively complicated, so practitioners must gain a firm grasp of the area of tax transfers of partnership interests. The examples in the regulations are oversimplified compared with real-life situations.

Identifying a disguised sale is not as simple as applying a formula and "filling in the blanks." The complex fact sets surrounding the circumstances demands practitioners who deal with partnerships have a strong working knowledge of whether a situation is a disguised sale.

Issue identification is important. There may be a disposition, a disguised sale or a “mixing bowl” type of transaction, any of which can trigger gain recognition.

Listen as our panelists dive into the rules related to disguised sales, mixing-bowl transactions, and contribution and distribution transactions between a partner and the partnership; analyses used by the IRS and courts to deem business deals as disguised sales; and abusive situations that trigger taxable events.

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Outline

  1. Analysis of applicable IRC sections
  2. Transactions likely to be problematic or permissible for tax purposes
    1. Disguised sales
    2. Mixing-bowl transactions
  3. 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
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

Thomas I. Hausman
Thomas I. Hausman

Schneider Smeltz Ranney & LaFond

Mr. Hausman specializes in tax, partnership and corporate practice, and estate planning. He counsels clients...  |  Read More

Bruce Belman
Bruce 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

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