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AICPA & CIMA ENGAGE 2021


TAX2114 - TAX2114. Partnership Tax Update Including Partnership Distressed Debt Workout Issues


Jun 10, 2021 1:30pm ‐ Jun 10, 2021 2:45pm

Description

  • Opportunities invited by recent legislation and final regulations governing partnership and partner business interest expense.
  • Strategies for avoiding the TCJA three-year holding period rule on carried interests in light of recent final regulations. 
  • Maximizing buy-in partner section 743(b) induced bonus depreciation including new leeway due to IRS removal of the "Partnership Lookthrough Rule".
  • Lessons from 2020 Tax Court decision, Bordelon, on partner/LLC member guarantees.
  • Challenges posed by the new K-1 "Capital Account" reporting requirements.
  • Tax advantages of exchanging debt for a partnership interest rather than modifying the loan.   
  • When is a purported partner loan really a partnership interest?  Why the distinction matters. 
  • The role of section 704(b) capital account revaluations in negotiating partner buy-ins

Learning Objectives:
  • Understand opportunities to minimize a partnership and partner's business interest expense.
  • Understand how carried interest partners can avoid the three-year holding period rule.
  • Learn the challenges posed by the new K-1 "capital account" reporting rules.
  • Understand strategies for handling distressed partnership debt.

Speaker(s):

  • Gary R. McBride, CPA and Attorney, Emeritus Professor, California State University East Bay
Tags: TAX
Category: Concurrent Session (Onsite and Online)

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