IRS Final Regulations Addressing Partnership Recourse Liability and Related Party Rules
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a thorough analysis of recently issued IRS final regulations addressing partnership recourse liability and related party rules. The panel will discuss key provisions of the final regulations and provide a practical guide to the challenges of allocating recourse and nonrecourse partnership debt, including a critical review of the rules and regulations under IRC Sections 704 and 752 in light of the final regulations.
Outline
- Overview of Sections 704 and 752
- Final IRS regulations
- Recourse versus nonrecourse debts
- Allocation of liabilities
- Bottom-dollar guarantees
- Disguised sales
- Key considerations for partnership agreements
Benefits
This panel will review these and other important topics:
- Key components of the final regulations on partnership recourse liability and related party rules
- Distinguishing recourse from nonrecourse partnership debt
- Application of debt allocation rules to everyday business transactions such as leveraged partnerships and asset drop-down transactions
- Allocating liabilities between partners
- Identifying disguised sales under the current tax law and final regulations
- Key considerations for partnership agreements
Faculty
Dr. Daniel Z. Altman
Partner
Sidley Austin
Dr. Altman represents clients with respect to all tax aspects of domestic and cross-border M&A and... | Read More
Dr. Altman represents clients with respect to all tax aspects of domestic and cross-border M&A and corporate restructuring transactions, including tax free and taxable transactions, stock and asset sales, mergers, bankruptcy restructuring, spin-offs, recapitalizations, joint ventures, inbound and outbound investments, and IP structuring and utilization. He provides tax advice in a variety of fields, including life insurance, property and casualty insurance, IP, healthcare, real estate, manufacturing, services, asset management, and others. Dr. Altman also advises clients on all international aspects of U.S. federal income taxation and assists clients in their international tax planning.
Close
Mark A. Melton
Partner
Holland & Knight
Mr. Melton is a tax attorney in Holland & Knight's Dallas office and serves as the co-chair of the... | Read More
Mr. Melton is a tax attorney in Holland & Knight's Dallas office and serves as the co-chair of the Tax, Executive Compensation and Benefits Practice Group. He focuses on federal income taxation issues related to domestic and international transactions of private equity and hedge funds, as well as other investment partnerships, joint ventures, real estate investment trusts (REITs) and operating businesses. More specifically, Mr. Melton assists clients with investment fund formation, mergers and acquisitions (M&A), real estate investment and development, and financial instruments and derivatives. He is experienced in a broad spectrum of tax issues such as complex partnership allocations, inbound and outbound cross-border investments, and investments by sovereign wealth funds, tax-exempt entities, international organizations and other institutional investors.
Close
Cannot Attend March 11?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.