Partnership Non-Cash Property Distributions: Hot Assets, Disguised Sales, and Other Critical Tax Challenges
Structuring Partnership Distributions Without Triggering Gain Recognition Under Secs. 704(c), 707, 731(c), 737, 751, and 752
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will guide tax professionals on the tax issues stemming from partnership non-cash property distributions. The panel will discuss critical issues in structuring non-cash property distributions, key exceptions, questions in applying Sections 751, 704(c), 707, 731(c), 737, and 752, and other items to avoid tax liability on distributions.
- Non-cash property distributions in corporations vs. partnerships
- Critical issues in structuring non-cash distributions
- Sec. 751(b) hot asset rules
- Sec. 707(a)(2)(B) disguised sale rule
- Triggering gain on distributions of contributed property: Secs.704(c) and 737
- Marketable securities; Sec. 731(c)
- Reduction in liability share under Sec. 752(b)
- Best practices in structuring non-cash partnership distributions to avoid gain recognition
The panel will review these and other key issues:
- How do non-cash distributions differ in a corporation vs. a partnership?
- What are the principal issues in structuring non-cash partnership distributions?
- What issues are presented under Sec. 751(b) hot asset rules?
- How can you ensure that a transaction avoids the application of Sec. 707(a)(2)(B) disguised sale rules?
- What rules apply to distributions of contributed property and marketable securities?
- How can gain recognition be triggered if the exchange of property results in a reduction of a partner's share of liabilities?
Benjamin W. Hager
Frost Brown Todd
Mr. Hager's practice includes the areas of business entity formations, mergers and acquisitions, reorganizations,... | Read More
Mr. Hager's practice includes the areas of business entity formations, mergers and acquisitions, reorganizations, operational tax issues and tax-efficient restructuring and exit strategies. A substantial part of his practice involves joint ventures, limited liability companies and partnerships, including within the context of venture capital, private equity and real estate equity funds.Close
Martin E. Mooney
Frost Brown Todd
Mr. Mooney practices in the individual and business tax areas and has extensive experience representing partnerships,... | Read More
Mr. Mooney practices in the individual and business tax areas and has extensive experience representing partnerships, limited liability companies, and corporations on issues ranging from formation to exit strategies, including reorganizations, mergers, acquisitions, redemptions, and consolidated return issues. Clients in his business practice range from sole proprietors to publicly held companies.Close