Structuring Contributions of Appreciated Property to Partnerships: Avoiding Tax Recognition on Built-In Gain Assets
A live 90-minute premium CLE/CPE video webinar with interactive 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 panel will discuss the specific tax treatment of appreciated property's contribution with debt, depreciation allocation, both liquidating and nonliquidating distributions, and capital account adjustments and allocations.
- General nonrecognition rules
- Current tax consequences for the contribution of appreciated property with debt encumbrance
- Basis adjustments required by the partnership
- Impact of distributions to contributing partner
- Impact of recently proposed tax law changes
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?
- What impact will the recently proposed tax law changes have on these rules?
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
to be announced.
Cannot Attend January 5?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.