Recourse and Non-Recourse Debt for Partnerships
Minimizing the Tax Impact of Partner Liability and Debt Allocations Under Sections 752 and 704
Recording of a 110-minute CPE webinar with Q&A
This course will prepare accounting advisors and tax preparers to make the difficult and complex distinction between recourse and non-recourse debts for partnerships. The panel will explain how to account for those debts in a partner’s tax basis under IRC §§752 and 704.
- Overview of §754 terms on liabilities, §704(b) terms on allocations
- Allocation of taxable income
- Definitions of recourse, non-recourse liabilities
- Allocations attributable to each type of liability
- Distinguishing recourse and non-recourse liabilities
- Interplay between §§754 and 704(b)
- Special tax issues
- COD income vs. Tufts gain
- Abandonment of interest
- Other tax issues
Our panel will review these and other key issues:
- How the distinctions between recourse and non-recourse liabilities affect partnership allocations.
- How Section 752 rules on sharing partnership liabilities can interact with Section 704(b) rules on partnership allocations.
- How non-recourse debt can be addressed when it has a negative tax impact.
- When a minimum gain charge-back should be considered.
Mr. Stein advises on corporate, partnership, and international tax issues. He has represented buyers and sellers in... | Read More
Mr. Stein advises on corporate, partnership, and international tax issues. He has represented buyers and sellers in mergers and acquisitions, investment fund sponsors and institutional investors with respect to investment fund formation, and financial institutions with respect to securities offerings, financings, and financial instruments.Close
Edward S. Wei
Cadwalader Wickersham & Taft
Mr. Wei's a transactional lawyer with significant expertise in the tax aspects of domestic and cross-border... | Read More
Mr. Wei's a transactional lawyer with significant expertise in the tax aspects of domestic and cross-border transactional matters, including taxable and tax-free mergers and acquisitions, spin-offs, bank financing arrangements, investments, partnerships and joint ventures, bankruptcy reorganizations, debt restructurings and securities issuances.Close
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