Tax Issues in Transferring LLC and Partnership Interests

Navigating the Complex IRS Rules for Buying, Selling or Redeeming Partnership Interests

Recording of a 90-minute CLE/CPE webinar with Q&A


Conducted on Thursday, March 2, 2017

Recorded event now available

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Program Materials

This CLE/CPE webinar will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions.

Description

For the unwary and unprepared, tax treatment of LLCs and partnerships is fraught with confusion and problems. Ownership interests in these entities are often compared to corporate shares, but there are many important distinctions. Tax basis, holding periods, and character of gain or loss are some of the characteristics determined by different rules.

Evaluating the tax consequences of a sale or disposition of an LLC or partnership interest often requires consideration of whether the interest being transferred is a profits interest or a capital interest, whether an interest is subject to vesting, and the character and holding period of the assets held by the partnership. To avoid unfavorable tax consequences, tax counsel must know how to evaluate tax treatment of LLC and partnership interest transfers.

Listen as our panel of experienced tax attorneys examines the complex tax rules for transferring LLC and partnership interests and best practices for structuring transactions to obtain desired tax outcomes.

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Outline

  1. Tax rules related to sales or transfers of LLCs or partnership interests
  2. Common issues and uncertainty related to the tax code
  3. Best practices

Benefits

The panel will review these and other key issues:

  • What tax differences result from choosing between a sale or redemption of a departing partner’s interest?
  • Will a sale or redemption of other partners create a taxable event to the remaining owners?
  • How is character of gain or loss determined upon a transfer?
  • What are the holding period and basis rules for transfers of partial interests?
  • What is the impact of the Net Investment Income Tax?

Faculty

Immerman, Andrew
L. Andrew Immerman

Partner
Alston & Bird

Mr. Immerman concentrates on federal income tax matters, including domestic and international tax planning and...  |  Read More

Mandarino, Joseph
Joseph C. Mandarino

Partner
Smith Gambrell & Russell

Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of...  |  Read More

Wilson, Amanda
Amanda Wilson

Partner
Lowndes Drosdick Doster Kantor & Reed

Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety...  |  Read More

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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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