Structuring Redemptions of Partnership and LLC Interests: Issues Unique to Liquidating Distributions
IRC 754 Elections, Section 736(b) Payments, Character and Timing of Gain, Installment Sales, and More
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will provide tax counsel and advisers with specific and practical guidance to navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss common pitfalls and uncertainties under current tax law and outline best practices to structure transactions.
- Redemption transactions and Section 736(b) payments
- Treatment of Section 751 "hot assets" in redemption transactions
- Section 736(a) payments to general partners
- Installment sale treatment of partnership redemptions
- Liquidating distributions of property rather than cash
- Section 754 elections in effect or not in effect
- Stuffing allocations before redemption
- Disguised sale risks
The panel will review these and other challenging issues:
- Distinguishing between redemption and a sale of a partnership interest by the redeeming partner to another partner(s)
- Under what circumstances would a redemption be disadvantageous to the partnership or the remaining partners?
- How the basis adjustment rules that apply when a Section 754 election is in effect function in redemption as opposed to a sale of a partnership interest
- Applying the Section 751 "hot asset" rules to the redeeming partner
- Differences in the character of gain or loss between redemption and other sale transactions
- Filing considerations when a partner is redeemed
- How Section 736(b) applies to payments to the redeeming partner
- Treatment of distributions of partnership property (including cash) and deemed cash distributions arising from a reduction in partnership liability allocations under Section 752
Winston & Strawn
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.Close
Winston & Strawn
Mr. Pesavento focuses his practice on tax matters.| Read More
Mr. Pesavento focuses his practice on tax matters.Close
Cannot Attend October 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.