The Revised Debt-for-Equity Exchange Regulations: Compliance Challenges
Anticipating Issues in Valuations of Partnership Interests Received, Bad Debt Deductions, Interest-Ordering and More
Recording of a 110-minute CPE webinar with Q&A
This teleconference will prepare advisors to deal with the most challenging aspects of the finalized Sect. 108(e)(8) regulations on partnership debt-for-equity exchanges.
Final debt-to-equity rules under Sect. 108(e)(8)
- General rules
- Valuation of partnership interest received
Application of Sect. 721
- Holding period
- Bad debt deduction to the creditor
- Exception to Sect. 721 treatment
- Interest-ordering rules
Practical strategies to consider
- Adjusting liquidation value
- Related-party acquisitions
The panel will offer insights and alternatives for dealing with these and other more complex aspects of the regulations:
- COD income of a partnership transferring an interest to a creditor.
- Fair market value of a partnership interest transferred to a creditor.
- Bad debt deductions to a creditor.
- The interest-ordering rules.
- Related-party acquisitions.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Tax Practice Director
Reynolds Hix & Co.
He has more than 30 years of tax experience and specializes in partnership and closely held business taxation. He is a... | Read More
He has more than 30 years of tax experience and specializes in partnership and closely held business taxation. He is a frequent writer and instructor on tax topics.Close