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.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
What Is Sec. 751 and When Does It Come Into Play
- Overview and History of Sec. 751 Under the Aggregate Theory of Taxation
- Sec. 751(a) - Transfer of Partnership Interest
- Sec. 751(b) - Distribution of Partnership Property
- Hot Assets
- Unrealized Receivables
- Inventory
- Substantially Appreciate Inventory
Review of the Sec. 751 Regulations and Other Authorities
- Overview of Existing Regulations
- Overview of 2014 Proposed Regulations
- Discussion of Primary Areas for Which Guidance Remains Lacking
Illustrate the Application of Sec. 751 in the Context of Typical Transactions
- Potential Structure Considerations and Alternatives
- Buyer and Seller Negotiating Points
- Form 8308 and Other Reporting Requirements
- Potential Sec. 751 Impact on a Sec. 736 Transaction
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on December 23, 2019.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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