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Guidance on Partnership Disguised Sales and Liabilities

Gain a better understanding of the updated rules on partnership disguised sales and liability allocation.

Partnership structures are becoming more common in transactions across all industries. The use of partnerships presents considerable tax complexity and planning opportunities. The tax rules governing the formation and operation of partnerships can be a trap for the unwary, in part because these rules differ from the tax rules governing corporations, to which many taxpayers are accustomed. This topic will help you understand the rules governing property contributions and liabilities associated with partnerships, and in particular identify many common issues that taxpayers confront when forming and operating partnerships. Moreover, the information will provide practical solutions to taxpayers seeking to effectively utilize partnerships in their industry.

Runtime: 98 minutes
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Over 31 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

Partnership Liabilities Under Section 752 - Background

  • Recourse Liabilities
  • Nonrecourse Liabilities
  • Guarantees and Bottom Dollar Guarantees

Disguised Sales Under Section 707 - Background

  • In General
  • Reimbursement of Preformation Expenditures
  • Qualified Liabilities
  • Debt Financed Distributions
  • Excess Nonrecourse Liabilities

Regulation Packages

  • 2014 Proposed Regulations on Sections 707 and 752
  • 2016 Final Regulations on Section 707
  • 2016 Temporary Regulations on Sections 707 and 752
  • 2016 Proposed Regulations on Section 752, Bottom Dollar Payment Obligations and Deficit Restoration Obligations

Some Strategies to Consider in Light of the 2016 Section 707/752 Regulations

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Why Lorman?

Over 31 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 Webinar

This course was last revised on November 10, 2017.

Call 1-866-352-9540 for further credit information.

  • Enrolled Agents 2.0
     
  • This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • GA CLE 1.7
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • NY CLE 2.0 including Areas of Professional Practice 2
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • NY CLE 2.0 including Areas of Professional Practice 2
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 31 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

Sam Kamyans

Sam Kamyans

Baker McKenzie

  • Associate in Baker McKenzie 's Tax group in Washington, D.C.
  • Practice focuses on the U.S. Federal income taxation of partnerships engaged in domestic and international transactions in a wide array of industries
  • Advises clients in the energy, private equity and real estate sector on structuring and implementing complex mergers and acquisitions, divestitures, equity extractions, internal restructurings, and public and private offerings, all with a strong focus on providing tax solutions
  • Experienced in the taxation of partnerships, and has significant experience in energy (traditional and renewable sources), private equity and public market transactions
  • Prior to joining the firm, he was tax counsel to Sempra Energy, a Fortune 500 energy company; before going in-house, he practiced at a large law firm and was an attorney advisor at the U.S. Internal Revenue Service, where he focused on partnership taxation. In addition to practicing tax law, he taught partnership taxation at Georgetown University Law Center from 2010 to 2015
  • Member American Bar Association - Tax Section and Washington D.C. Bar Association - Tax Section
  • LL.M. degree, with distinction, Georgetown University Law Center; J.D. degree, Loyola Law School; B.S. degree, University of California at Santa Barbara
Patricia W. McDonald

Patricia W. McDonald

Baker McKenzie

  • Partner at Baker McKenzie
  • Practice focuses on Federal tax issues and tax planning for corporations, partnerships, limited liability companies and other passthrough entities
  • Regularly advises clients on tax structuring and other tax issues in various transactions and structures, including domestic and cross-border mergers and acquisitions, inbound real estate and investment fund transactions, and transactions involving partnership and limited liability company structures
  • Advises clients on tax matters relating to transactions in the renewable energy sector, such as the use of energy tax credits and energy grants in capital structures
  • Has given a number of presentations on partnership tax issues, tax issues relating to mergers and acquisitions, and international tax issues; she has presented at seminars sponsored by the Tax Executives Institute, the American Bar Association, the Alliance for Tax, Legal and Accounting Seminars, the Council for International Tax Education, and the Chicago Bar Association
  • Member of the American Bar Associationís Section of Taxation
  • J.D. and M.B.A. degrees, University of Notre Dame; B.A. degree, University of Chicago
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Why Lorman?

Over 31 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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Product ID: 400202
Published 2017
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