Tax Implications of Transactions Between Partners: IRC 704(c)(1)(B), 707, 737, and 751(b)
Navigating the Complex Disguised Sales Rules
Recording of a 110-minute premium CLE/CPE webinar with Q&A
This CLE course will provide tax counsel with clarification of gain/loss recognition rules of IRC Sect. 704(c)(1)(B) and Sect. 737 for partnerships. Our panel will discuss the general rules of applicability and exceptions, review characterization rules, and offer best practices for dealing with other compliance challenges.
Recognition of gain/loss rules
- Section 704(c)(1)(B)
- Section 737
- Effect of post-contribution gain
- Ordinary vs. capital
- Partnership mergers
- Other exceptions
The panel will review these and other key questions:
- What are the key reporting rules of IRC Sections 704(c)(1)(B) and 737?
- What exceptions apply to the reporting rules?
- How is the gain/loss characterized in partner transactions involving contributed property?
- What are critical challenges and subtleties involved in tax planning and reporting partner transactions under IRC Sections 704(c)(1)(B) and 737?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Belan K. Wagner
Wagner Kirkman Blaine Klomparens & Youmans
Mr. Wagner has over 35 years of in-depth experience in business, taxation, tax planning and controversy resolution,... | Read More
Mr. Wagner has over 35 years of in-depth experience in business, taxation, tax planning and controversy resolution, mergers and acquisitions, real estate, and estate planning. He provides direct representation to business owner clients, frequently structured as pass-through entities, and also acts as an expert resource to their primary attorneys, accountants and other representatives.Close
Mr. Keinan has more than 15 years of experience in U.S. and Israel federal tax law and specializes in U.S. and... | Read More
Mr. Keinan has more than 15 years of experience in U.S. and Israel federal tax law and specializes in U.S. and international taxation of financial products and institutions. Before coming to Greenberg Traurig, he worked as a national tax senior manager at Ernst & Young. He chairs the ABA Tax Section's Banking Committee.Close