Partnership Tax and Disguised Sales

Navigating Section 707 to Determine Classification of Partners' Contributions and Distributions

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, February 13, 2013

Recorded event now available

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Course Materials

The course will increase tax return preparers' familiarity with issues involved in classifying partners’ contributions, distributions and other transactions as disguised sales. The panel will focus on the application of disguised sale rules and ways that an otherwise non-taxable distribution may be taxable.

Description

The issue of when a transaction between a partner and a partnership is subject to the disguised sale rules under Sections 707(a)(2), 704(c)(1)(B),737 or 751(b) can be fraught with confusion. For practitioners who deal with partnerships, these matters are critical.

Tax preparers must focus on the circumstances of the transaction, and determine whether the business deal may be viewed as a disguised sale, thereby triggering a taxable event.

Listen as our experienced panel reviews the rules and offers guidance affecting a tax return preparer's work related to disguised sales, contribution and distribution transactions between a partner and the partnership, the analyses used by the IRS and courts to deem business deals as disguised sales, and abusive situations triggering taxable events.

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Outline

  1. Analysis of IRC Section 707(a)(2), 704(c)(1)(B), 737 or 751(b)
  2. Transactions likely to be problematic or permissible for tax purposes
  3. Issues of importance to return preparers

Benefits

The panel will review these and other key questions:

  • What are the key challenges for tax preparers as a result of contribution and distribution transactions between partners and the partnership?
  • What transactions are most likely to trigger disguised sale and anti-abuse rules—and result in taxable events?
  • How do the provisions of Section 707 distinguish between partnership-partner transactions that are taxable events and those that are not?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Faculty

Jesica Speer
Jesica Speer
Tax Manager
Grant Thornton

She works primarily with closely held businesses and their owners on personalized tax savings strategies, technical...  |  Read More

Wagner, Belan
Belan K. Wagner
Managing Partner
Wagner Kirkman Blaine Klomparens & Youmans

Mr. Wagner has over 35 years of in-depth experience in business, taxation, tax planning and controversy resolution,...  |  Read More

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