Recourse and Nonrecourse Liability in Partnership Agreements
Leveraging Section 752 to Minimize Tax Impact of Partnership Liability and Debt Allocations
Recording of a 110-minute CLE/CPE webinar with Q&A
This webinar will provide tax counsel with clarification on the complexities of characterizing partnership liabilities as recourse or nonrecourse. The panel will also explain the significant tax and economic consequences for partners caused by distinctive treatments under the Tax Code and Regulations.
- Overview of IRC Section 752 liabilities and interplay with Section 704 allocations
- Distinguishing recourse v. nonrecourse liabilities and debt
- Recent transactions and cases interpreting 752 allocations
- Planning techniques and strategies
The panel will review these and other key questions:
- How are partnership allocations affected by the distinctions between recourse and nonrecourse liabilities?
- What is the interplay between IRC Sections 752 and 704?
- How can counsel effectively draft language to address nonrecourse debt?
- What situations call for consideration of minimum gain chargeback provisions?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Andrew W. Ratts
Winston & Strawn
He advises clients on tax issues relating to business formations, acquisitions, divestitures, debt reorganizations... | Read More
He advises clients on tax issues relating to business formations, acquisitions, divestitures, debt reorganizations and executive compensation. He has particular experience with the federal income taxation of pass-through entities, such as partnerships, limited liability companies, S corporations and grantor trusts, and of financial instruments and derivatives.Close
Jon R. Stefanik
Buckingham Doolittle & Burroughs
He focuses his practice on tax planning and consulting, as well as on taxpayer representation before the IRS and... | Read More
He focuses his practice on tax planning and consulting, as well as on taxpayer representation before the IRS and state taxing authorities. His experience includes analysis of a wide range of tax issues, including issues related to LLC and partnership taxation, estate and gift taxation, corporate taxation and state and local taxation.Close