Structuring Contributions of Appreciated Property to Partnerships: Avoiding Tax Recognition on Built-in Gain Assets
Navigating Allocation Challenges, the "Seven Year Rule" of Section 737, and New Debt Classification Regs
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel with a comprehensive guide to the tax consequences of contributing appreciated property to a partnership or multi-member LLC. The event will present a framework of the specific tax treatment of the contribution of appreciated property with debt, allocation of depreciation, both liquidating and nonliquidating distributions, and capital account adjustments and allocations.
- General nonrecognition rules
- Current tax consequences for contribution of appreciated property with debt encumbrance
- Basis adjustments required by partnership
- Impact of distributions to contributing partner
The panel will discuss these and other important topics:
- Under what circumstances would contribution of appreciated property not qualify for nonrecognition under Section 721?
- What is the “seven year rule” of Section 737 and how does it impact distributions to partners who have previously contributed appreciated property subject to debt encumbrance?
- What is the impact on the contributing partner when the partnership distributes the appreciated property to other partners?
L. Andrew Immerman
Alston & Bird
Mr. Immerman concentrates on federal income tax matters, including domestic and international tax planning and... | Read More
Mr. Immerman concentrates on federal income tax matters, including domestic and international tax planning and transactional work for joint ventures, partnerships, limited liability companies and corporations. He has helped structure many sophisticated partnership and limited liability company transactions and has represented the target or the acquirer in numerous corporate mergers and acquisitions.Close
Joseph C. Mandarino
Smith Gambrell & Russell
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of... | Read More
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino writes and speaks extensively on a wide range of business, tax and finance topics.Close