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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
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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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