Partnership Debt Allocations and New IRS Regulations: Minimizing Tax Consequences
Bottom-Dollar Guarantees, Disguised Sales, Recourse and Nonrecourse Debt Allocations
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a thorough and practical guide to the challenges of allocating recourse and nonrecourse partnership debt, including an analysis of the Treasury regulations issued in October 2019.
Outline
- Background on Sections 707 and 752
- Overview of the newest regulations
- Liability allocations
- Bottom-dollar guarantees
- Disguised sales
- The partnership agreement
- Examples
Benefits
This panel will review these and other key issues:
- Distinguishing recourse from nonrecourse partnership debt
- Allocating liabilities between partners
- The impact of the new regulations on common partnership transactions
- Identifying disguised sales under the newest regulations
- Steps tax advisers should take in light of the latest regulations
Faculty
Glenn Dance
Partner
Holthouse Carlin & Van Trigt
Mr. Dance has over 35 years of public accounting experience. He specializes in complex partnership taxation and is an... | Read More
Mr. Dance has over 35 years of public accounting experience. He specializes in complex partnership taxation and is an integral addition to the firm’s Private Equity and Real Estate industry niche practices. Mr. Dance began his career in public accounting at Arthur Andersen and was admitted to their partnership where he led their Partnership Tax Specialty Group. His public accounting experience also includes a tenure at EY where he was a partner in their Joint Venture and Partnership Tax Services Group and served as head of their Master Limited Partnership Tax Practice. Mr. Dance was most recently with Grant Thornton as a managing director in their Partnership Tax Group. Additionally, he served as special counsel to the IRS Associate Chief Counsel in the Pass-thrus and Special Industries group. Mr. Dancen has taught partnership tax at Golden Gate University, the University of Southern California, The Georgetown University Law Center and the Villanova School of Law.
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Joseph C. Mandarino
Partner
Smith Gambrell & Russell
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of... | Read More
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino’s practice also includes representation in tax controversy work. He writes and speaks extensively on a wide range of business, tax and finance topics.
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Kim Palmer, CPA, MT
Partner
Cohen & Company
Ms. Palmer leads the firm’s Partnership Tax Group. She focuses on tax issues primarily relating to the real... | Read More
Ms. Palmer leads the firm’s Partnership Tax Group. She focuses on tax issues primarily relating to the real estate industry, including commercial, industrial, self-storage and multi-family, as well as real estate funds; clients renting telecommunications equipment; and clients structured as partnerships that fall into many other industries. Ms. Palmer assists clients with complex restructuring transactions, including the purchase/sale of assets and ownership interests, buyouts between owners, issuance of ownership interests and debt restructuring transactions. Other areas of expertise include like-kind exchanges, partnership transactions, exit strategies, disguised sale transactions, waterfall allocations and transactions, and UPREIT and REIT transactions.
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