DVDS-W01
LLCs & Partnerships - Distributions Under IRC Section 731

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Date/Time: Monday, November 5, 2012, 1-3 p.m. Eastern (see all dates)

Presenter(s): Michael Tucker, CPA, Bob Lickwar, CPA, MST

Tax practitioners should be up-to-date on the rules governing both partnership distributions and disguised sales as both sets of rules might appear to cover the same distribution. Unless the tax professional is able to tell when the disguised sale rules trump the general partnership distribution rules, the tax practitioner might be led to give wrong advice regarding the taxability or nontaxability of a particular distribution.

This program covers the general partnership distribution rules for both current and liquidating distributions, and then explores the circumstances where the so called "disguised sale" rules apply to make an otherwise nontaxable distribution taxable.

Major Topics:

• Taxation of current and liquidating partnership distributions
• Tax treatment of cash distributions
• Generic tax treatment of non-cash property distributions
• When gain or loss is generally recognized on a partnership distribution
• Disguised sale rules generally
• Circumstances under which gain will be recognized to a contributing partner when contributed property is distributed to a noncontributing partner
• Taxable distributions to partners who have contributed other property to the partnership

Learning Objectives:

• Determine if a partnership distribution is subject to the disguised sale rules or is subject to the general partnership distribution rules under Section 731

Designed For:

• Any tax practitioner who wishes to understand the tax rules and IRS guidance relating to partnership distributions
• Any tax practitioner wishing to be updated with how to differentiate between a general partnership distribution and a disguised sale

Course Level: Advanced

CPE Credits: 2, Taxes

Prerequisite: General background in the taxation of partnership income taxation

Advance Preparation: None

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