Gain insight into the issues presented when you are involved in the construction, structuring, and/or reporting of ownership transactions.
IRC Sec. 751 contains some of the more difficult rules to navigate in Subchapter K, and have potential implications with every partnership/LLC ownership transaction. The aggressive bonus depreciation rules of recent years increase the potential for Sec. 751 implications. Likewise, the proliferation of disproportionate allocation structures and the use of different classes of ownership interests increases the complexities inherent in trying to apply Sec. 751 to actual transactions. This topic will give you the information you need to be conversant in the issues presented when you are involved in the construction, structuring, and/or reporting of ownership transactions.
Agenda
Faculty
Joseph Schlueter
Baker Tilly Virchow Krause, LLP
- Tax director in the Minneapolis office of Baker Tilly Virchow Krause, LLP
- Over 30 years of experience in public accounting, and over 20 years as a national tax resource in national accounting firms on all matters related to the taxation of partnerships
- Extensive experience advising small, middle market and closely held business clients on structuring acquisition, disposition, and ownership succession transactions and the related tax implications
- Active for more than 20 years in preparing and presenting webcasts and seminars for CPE and CLE organizations
- J.D. degree, University of Iowa, College of Law; B.A. degree in accounting, University of Northern Iowa
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