New IRC 721(c) Regulations and Contributions to Foreign Partnerships
Remedial Allocations and Structuring Transfers to Foreign Partnerships to Ensure Gain Deferral
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel with a detailed and practical guide to the rules governing contributions by U.S. persons to “related foreign partnerships,” particularly in the wake of new IRC 721(c) Treasury Regulations, which effectively end non-recognition treatment of partnership contributions if a US person contributes appreciated property to a partnership (US or foreign) in which the US person and related foreign persons own 80 percent or more of the partnership’s interests. The panel will review the specific changes the new regulations make to the previous rules found in Notice 2015-54, and offer guidance on allocation methods on covered contributions.
Outline
- Default rules on contributions to partnerships
- Treas. Reg. TD 9814, Transfers of Certain Property by U.S. Persons to Partnerships with Related Foreign Partners
- Gain deferral method and remedial allocations
- Structuring contributions to partnerships
- Reporting requirements for property contributions to partnerships
Benefits
The panel will review these and other key issues:
- What is the default deferral treatment of contributions to partnerships?
- Determining when a property transfer to a partnership requires recognition of built-in appreciation
- Structuring contributions to 721(c) partnerships to apply gain deferral method
- Understanding remedial allocations applied to contributed property
Faculty
Richard Blumenreich
Principal-in-Charge
KPMG
Mr. Blumenreich is principal-in-charge of the Washington National Tax Credit and Energy Advisory Services Group. For... | Read More
Mr. Blumenreich is principal-in-charge of the Washington National Tax Credit and Energy Advisory Services Group. For his prior 20 years at KPMG, he was a principal in the Washington National Tax Passthoughs Group. He focuses primarily on tax issues relating to tax credits, partnerships, depreciation, amortization of intangibles, and leasing. Prior to joining KPMG, he was with the Internal Revenue Service’s Office of Chief Counsel where he was an Assistant Branch Chief in the Office of the Assistant Chief Counsel (Passthroughs & Special Industries) and an Attorney-Advisor in the Legislation and Regulations Division. While at the IRS, he worked extensively on regulations and rulings regarding the taxation of partnerships, depreciation, and tax credits.
CloseMorgan Holtman
Director, Passthroughs Group
KPMG
Ms. Holtman's practice focuses on cross-border partnership matters with particular emphasis on complex equity... | Read More
Ms. Holtman's practice focuses on cross-border partnership matters with particular emphasis on complex equity structures, special allocations, and mergers and acquisitions. Her experience includes advising clients on partnership formation, operation, and liquidation issues; coordinating with non-U.S. tax advisors on multi-jurisdictional partnership transactions; advising clients on the tax implications of partnership agreements; advising and representing clients on partnership tax matters in financial accounting audits; and providing partnership tax training for client and firm personnel.
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