Show navigation

Live Webinar

60-minute live streaming program
  • December 23
  • 1:00 - 2:00 pm EST

IRC 751 Hot Assets and the Sale of Partnership Interests

December 23

Gain insight into the issues presented when you are involved in the construction, structuring, and/or reporting of ownership transactions.

IRC Sec. 751 contains some of the more difficult rules to navigate in Subchapter K, and have potential implications with every partnership/LLC ownership transaction. The aggressive bonus depreciation rules of recent years increase the potential for Sec. 751 implications. Likewise, the proliferation of disproportionate allocation structures and the use of different classes of ownership interests increases the complexities inherent in trying to apply Sec. 751 to actual transactions. This topic will give you the information you need to be conversant in the issues presented when you are involved in the construction, structuring, and/or reporting of ownership transactions.

Learning Objectives

  • You will be able to discuss the potential application of Sec. 751 in a variety of ownership transaction settings.
  • You will be able to identify the hot assets within the LLC that will need to be considered when planning and completing a transaction.
  • You will be able to recognize when special reporting requirements exist for the LLC and its members.
  • You will be able to describe the difference between Sec. 751(a) and Sec. 751(b) applications.

Purchase Options

More Program Information

Why Lorman?

Over 32 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

What Is Sec. 751 and When Does It Come Into Play
  • Overview and History of Sec. 751 Under the Aggregate Theory of Taxation
  • Sec. 751(a) – Transfer of Partnership Interest
  • Sec. 751(b) – Distribution of Partnership Property
  • Hot Assets
    • Unrealized Receivables
    • Inventory
    • Substantially Appreciate Inventory
Review of the Sec. 751 Regulations and Other Authorities
  • Overview of Existing Regulations
  • Overview of 2014 Proposed Regulations
  • Discussion of Primary Areas for Which Guidance Remains Lacking
Illustrate the Application of Sec. 751 in the Context of Typical Transactions
  • Potential Structure Considerations and Alternatives
  • Buyer and Seller Negotiating Points
  • Form 8308 and Other Reporting Requirements
  • Potential Sec. 751 Impact on a Sec. 736 Transaction
Purchase Options

More Program Information

Why Lorman?

Over 32 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

Live Webinar Registration

  • AIPB 1.0
     
  • This program is acceptable for 1.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • AL CLE 1.0
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.0 hours credit.
     
  • AR CLE 1.0
     
  • This course has been approved for 1.0 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.0
     
  • The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. This activity may qualify for up to 1.0 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.0
     
  • Lorman Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.0 CLE hours of participatory credit.
     
  • CT CLE 1.0
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
     
  • HI CLE 1.0
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.0 CLE credit hours.
     
  • IL CLE 1.0
     
  • This course was approved for a total of 1.0 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.0
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.0 hours of CLE credit under M. Bar R. 12.
     
  • MT CLE 1.0
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.0 CLE credits.
     
  • NH MCLE 1.0
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 60 Minutes.
     
  • NJ CLE 1.2
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.2 hours of total CLE credit.
     
  • NV CLE 1.0
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.0 CLE hours.
     
  • PA CLE 1.0
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.0 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.0
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.0 hours of CLE credit.
     
  • TN CLE 1.0 (Pending)
     
  • This program has been submitted as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.0 hours of credit.
     
  • VT CLE 1.0
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hours of CLE credit.
     
  • WA CLE 1.0
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.0 hours of Law & Legal Procedure credit.
     
  • WI CLE 1.0
     
  • This program has been approved by the Board of Bar Examiners for 1.0 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.2
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.2 MCLE hours.
     
  • CPE 1.2 including Taxes 1.2
     
  • Lorman Education Services 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 credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 1.2 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 1.2 hours. Prerequisite: basic knowledge of general accounting. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, Inc. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Taxation for 1.0 hour.
     

Who should attend?

This live webinar is designed for accountants, CPAs, CEOs, presidents, vice presidents, CFOs, controllers, tax preparers, business owners and managers, bookkeepers, enrolled agents and attorneys.

Purchase Options

More Program Information

Why Lorman?

Over 32 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

Joseph Schlueter

Joseph Schlueter

Baker Tilly Virchow Krause, LLP

  • Tax director in the Minneapolis office of Baker Tilly Virchow Krause, LLP
  • Over 30 years of experience in public accounting, and over 20 years as a national tax resource in national accounting firms on all matters related to the taxation of partnerships
  • Extensive experience advising small, middle market and closely held business clients on structuring acquisition, disposition, and ownership succession transactions and the related tax implications
  • Active for more than 20 years in preparing and presenting webcasts and seminars for CPE and CLE organizations
  • J.D. degree, University of Iowa, College of Law; B.A. degree in accounting, University of Northern Iowa
Purchase Options

More Program Information

Why Lorman?

Over 32 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.

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
  • OnDemand Webinars
  • MP3 Downloads
  • Course Manuals
  • Audio Recordings*
  • Executive Reports
  • White Papers and Articles
  • Sponsored Live Webinars

Additional benefits include:

  • State Specific Credit Tracker
  • Members Only Newsletter
  • All-Access Pass Course Concierge

* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

Sign Up Today
With This Course

Access to all training products for one year
$699/year

Unlimited Lorman Training

With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!

Easy Registrations

Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.

Invest in Yourself

You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.

Product ID: 405449
Published 2019
Purchase Options

Register today before this event fills.