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

Category: Concurrent Session (Onsite and Online)