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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Partnership Distribution Rules and Exceptions: Key Issues for Tax Counsel, Planning Strategies to Minimize Liability

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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Description

Partnership distributions and sales of partnership interest can result in significant tax liability. Tax professionals must be able to navigate complex tax rules in order to identify key issues and implement strategies to minimize tax liability when structuring partnerships and related transactions.

Under Sec. 731(a), owners of an entity treated as a partnership for tax purposes do not recognize taxable gain or loss on a distribution unless the distribution exceeds their outside basis in the partnership interest. The same applies under Sec. 731(b) whereas the partnership does not recognize taxable gain or loss on distributions made to owners. However, both provisions are subject to certain exceptions that tax professionals must understand along with the potential implications regarding tax basis under Sec. 732.

Tax practitioners advising both the partnership making distributions and the owners receiving the distributions must implement methods to minimize the tax consequences of these transactions.

Listen as our panel discusses certain types of partnership distributions and related tax rules, exceptions to the nonrecognition rules, issues stemming from guaranteed payments, disguised sales, and other challenges.

Presented By

Leo Greenberg
Attorney
Skadden Arps Slate Meagher & Flom LLP

Mr. Greenberg represents domestic and international clients in an array of U.S. federal income tax matters. He advises public and private companies across industries on the buy-side and sell-side tax aspects of mergers and acquisitions. Mr. Greenberg also counsels multinational companies in the biopharmaceutical, technology, automotive, entertainment, insurance, energy, food and shipping industries on complex post-acquisition integration and cross-border tax planning. Additionally, he represents business clients in the tax aspects of public and private debt and equity offerings, redemptions, restructurings, intellectual property licensing and collaboration transactions, and bankruptcies. In recognition of his work, Mr. Greenberg was named an Up & Coming Lawyer in 2023 by Massachusetts Lawyers Weekly.

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Brian Kenney
Attorney
Nixon Peabody LLP

Mr. Kenney’s practice concentrates on mergers, acquisitions, private equity investments and fund formation matters, as well as state and local tax issues. He also focuses on financing community development projects through the use of tax credits and other financing sources.

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Shahzad Malik
Partner
Parent: Nixon Peabody LLP

Mr. Malik is a partner within Nixon Peabody’s Corporate & Finance practice group and a member of our Tax team. He concentrates on tax issues for mergers, acquisitions, private equity investments and fund formation matters as well as tax controversy issues.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, March 20, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Tax rules applicable to partnership distributions
  2. Navigating exceptions to the nonrecognition rules
    1. Guaranteed payments
    2. Distributions involving the "mixing bowl" rules
    3. Disguised sales
  3. Tax issues for liquidating distributions of cash or property
  4. Determining tax basis
  5. Best practices for counsel and taxpayers to minimize tax liability

The panel will discuss these and other key issues:

  • Tax treatment of the distribution to the partnership and any partners
  • General nonrecognition rules and exceptions
  • Potential tax implications of liquidating distributions of cash and property
  • Determining tax basis
  • Best practices for counsel and taxpayers to minimize tax liability

Learning Objectives

After completing this course, you will be able to:

  • Understand the tax treatment of distributions for partnerships, LLCs, and any partners
  • Recognize issues stemming from the nonrecognition rules and exceptions
  • Identify tax implications of distributions of cash and property
  • Ascertain key factors in determining tax basis stemming from distributions
  • 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 attendance verification prompts displayed throughout the program
  • 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 1031 Like-Kind Exchange rules

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .