Sweeping Section 752 Rule Changes for Recourse and Nonrecourse Partnership Liability Allocation
Incorporating New Net Value, Bottom-Dollar, Transition Rules and More
Recording of a 110-minute premium CLE/CPE webinar with Q&A
This CLE course will provide tax counsel with techniques to determine allocation of recourse and nonrecourse liabilities in light of new, coming IRS regulations. The panel will review the impact of the revisions for structuring partnership transactions and agreements, including new net value, bottom-dollar guarantee, transition rules and more.
Outline
- Overview of allocations of recourse and nonrecourse liabilities under current law
- Recourse liabilities under the proposed regulations
- Nonrecourse liabilities under the proposed regulations
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Issues
- Net value requirement
- Elimination of bottom-dollar guarantees
- Requiring payment for providing a guarantee
- Transition rules
- Best practices for changes to partnership agreements
Benefits
The panel will review these and other key questions:
- What changes will the proposed regulations make to the allocation of recourse and nonrecourse liabilities?
- How do the changes compare to the current regime? How will they affect future transactions and partnership agreements?
- What steps must be taken now to prepare for the changes proposed in the IRS regulations?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Gale E. Chan
Partner
McDermott Will & Emery
Ms. Chan focuses her practice on federal and international tax matters involving partnerships, LLCs and corporations.... | Read More
Ms. Chan focuses her practice on federal and international tax matters involving partnerships, LLCs and corporations. She has experience with bankruptcy related tax issues, nuclear decommissioning trust funds, tax accounting and change in method of accounting issues, captive insurance tax issues, and requesting IRS private letter rulings. She drafts tax opinions involving reorganizations and redemptions, and regularly represents clients in examination before the IRS and state taxing authorities.
CloseRobert A.N. Cudd
Senior Partner
Polsinelli
Mr. Cudd advises both domestic and foreign entities on tax-efficient structures as well as on transactions between the... | Read More
Mr. Cudd advises both domestic and foreign entities on tax-efficient structures as well as on transactions between the domestic and foreign entities. He has extensive experience in public and private REITs, timber and infrastructure funds, solar and wind projects, energy and pipelines, reorganization of domestic and foreign corporations and partnerships, private equity funds, controlled foreign corporations and PFICs, and bankruptcy and insolvency.
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