Related Party Notes and Transactions: Section 267, Imputed Interest, Disallowed Losses, and Like-Kind Exchanges
Recording of a 110-minute CPE webinar with Q&A
This course will examine the complexities of related party transactions for tax advisers working with closely held businesses and their owners. The panelist will explain when imputed interest is required, when it is recognized by the payor and payee, when loss deductions are disallowed versus deferred, and steps tax professionals can take to identify and properly report these affiliated transactions.
- Related parties and IRC Section 267
- Related parties under IRC Section 267(b)
- Related party loans
- Imputed interest
- Interplay with IRC Section 7872
- Application of NIIT, IRC Section 1411
- Ramifications of noncompliance
- Related party sales
- Loss disallowance
- Other transactions
- Installment sales
- Involuntary conversions
- Like kind exchanges
The panelist will cover these and other key issues:
- When imputed interest is required to be assessed between related parties
- How is the gain calculated on a subsequent sale of an asset when a loss was disallowed initially under Section 267?
- When is interest income and expense between related parties recognized by the payor and payee?
- What relationships constitute associated parties under Section 267(b)?
- How are like kind exchanges and installment sales affected when between related parties?
Michael A. Clements, CPA, CVA, MST
Paresky Flitt & Company
Mr. Clements brings more than 20 years of experience providing accounting and tax services to privately owned... | Read More
Mr. Clements brings more than 20 years of experience providing accounting and tax services to privately owned businesses including food service, bio-technology, manufacturing, real estate, and professional services. He brings additional expertise in the employee benefit plan audit area, providing audit and consulting services to various 401(k) plans and Employee Stock Ownership Plans.Close
Damien Falato, CPA, MST, CGMA
Paresky Flitt & Company
Mr. Falato has over fifteen years of public accounting experience, and is licensed as a CPA in MA & NJ. His... | Read More
Mr. Falato has over fifteen years of public accounting experience, and is licensed as a CPA in MA & NJ. His extensive experience includes tax planning and preparation, business consulting, trusts and estates, multi-state tax issues, succession, merger and acquisition planning.Close