Tax Issues in Transferring LLC and Partnership Interests
Navigating the Complex IRS Rules for Buying, Selling or Redeeming Partnership Interests
A live 90-minute CLE/CPE webinar with interactive Q&A
Thursday, March 2, 2017 (in 5 days)
1:00pm-2:30pm EST, 10:00am-11:30am PST
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.
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.
- Tax rules related to sales or transfers of LLCs or partnership interests
- Common issues and uncertainty related to the tax code
- Best practices
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?
After completing this course, you will be able to:
- Recognize the tax rules that apply to the sale or transfer of an LLC or partnership interest
- Discern common pitfalls and uncertainties in the tax code
- Identify issues that may lead to unfavorable tax treatment
- Determine best practices to structure transactions to achieve intended tax consequences
L. Andrew Immerman, Partner
Alston & Bird,
Mr. Immerman concentrates on federal income tax matters, including domestic and international tax planning and transactional work for joint ventures, partnerships, limited liability companies and corporations. He has helped structure many sophisticated partnership and limited liability company transactions and has represented the target or the acquirer in numerous corporate mergers and acquisitions.
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 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.
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 of complex federal tax matters, with a particular emphasis on pass-through entities such as partnerships, S corporations and real estate investment trusts. Specifically, she focuses on advising clients on the formation, operation, acquisition and restructuring of pass-through entities.
Live Webinar $297.00
Add a colleague on the same connection in the same room for only $97.00 in the shopping cart or by calling customer service.
This webinar is eligible for at least 1.5 general CLE credits.
CLE credits are not available for PR.
*In KS, OH, PA, for more than 1 attendee on the connection you must contact Strafford CLE via email or call 1-800-926-7926 ext. 35 prior to the program for special instructions.
CPE on Live Event
Continuing Professional Education credit processing is available for an additional fee per person. You may register for CPE credit processing at any time before or after the program. To qualify for CPE you may not listen via the telephone.
This program is eligible for 1.5 CPE credits.
- Field of Study: Taxes.
- Level of Knowledge: Intermediate.
- Advance Preparation: None.
- Teaching Method: Seminar/Lecture.
- Delivery Method: Group-Internet (via computer).
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
- Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex income tax forms and schedules for partnerships and pass throughs; supervisory authority over other preparers/accountants. Knowledge and understanding of partnership structures, dissolution and related taxation; Familiarity with sale and redemption of a departing partners interest, characterizing gain and loss determined upon a transfer, and the Net Investment Income Tax.
NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.
CLE On-Demand - Streaming Video
Note: Self-study CPE and EA credits are not offered on this On-Demand webinar.
Includes recorded streaming video of full program plus PDF handouts.
On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.
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*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.
**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.
CLE On-Demand Video $297.00
Available 48 hours after the live event
Includes full event recording plus handouts (available after live webinar).
Note: Self-study CPE and EA credits are not offered on recorded events.
Strafford is an approved provider and self-study CLE credit is available in most states.
AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
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Recorded Webinar Download $297.00
Available 48 hours after the live event
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Available 24 hours after the live event
DVD (Slide Presentation with Audio) $297.00
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Available ten business days after the live event
Registration Plus Recorded Event
Live Webinar & Webinar Download $394.00
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Live Webinar & Audio Download $394.00
Recorded Audio Download (MP3) Only $97.00 with Registration/MP3 Combo
Live Webinar & DVD $394.00 plus $9.45 S&H
DVD (Slide Presentation with Audio) Only $97.00 with Registration/DVD Combo
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I was pleased with the in-depth, comprehensive coverage of a fairly narrow but important set of issues.
Patricia L. Chapman
Very clearly presented and very practical advice.
Winthrop Rutherfurd, Jr.
White & Case
Concise and accurate presentation. Handouts very informative.
Strafford webinars are convenient and offer timely topics with knowledgeable presenters.
The presenters were knowledgeable and able to intelligently answer questions.
Mikunda, Cottrell & Co.
Tax Law Advisory Board
Steptoe & Johnson
Morrison & Foerster
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Holland & Knight
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Ivins, Phillips & Barker
Managing Director, State and Local Tax Practice
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
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