Recourse and Nonrecourse Liability in Partnership Agreements
Leveraging Section 752 to Minimize Tax Impact of Partnership Liability and Debt Allocations
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will guide tax counsel and advisers on navigating the complexities of characterizing partnership liabilities as recourse or nonrecourse. The panel will explain the significant tax and economic consequences for partners caused by distinctive treatments under the current tax code and regulations.
Outline
- Overview of IRC Section 752 liabilities and interplay with Section 704 allocations
- Distinguishing recourse vs. nonrecourse liabilities and debt
- Recent transactions and cases interpreting 752 allocations
- Planning techniques and strategies
Benefits
The panel will review these and other key issues:
- How are partnership allocations affected by the distinctions between recourse and nonrecourse liabilities?
- What is the interplay between IRC Sections 752 and 704?
- What are best practices for drafting language that addresses nonrecourse debt?
- What situations call for consideration of minimum gain chargeback provisions?
Faculty
Rebecca Lodovico
Tax Managing Director
BDO USA
Ms. Lodovico provides tax services to clients in a variety of industries, with a focus on closely held clients in the... | Read More
Ms. Lodovico provides tax services to clients in a variety of industries, with a focus on closely held clients in the real estate industry. While her primary concentration is in partnership taxation, she provides clients with a full range of tax and business consulting services. She also provides services in the firm’s National Tax Office Partnership Taxation Group. Services include research and consultation on a wide range of Subchapter K issues, including capital account maintenance, income and loss allocations, and liability allocations.
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Joseph F. Schlueter, JD, CPA
Tax Managing Director, National Partnership Group
BDO USA
Mr. Schlueter focuses his practice on tax and for the past 25 years has been in the tax department at a variety of... | Read More
Mr. Schlueter focuses his practice on tax and for the past 25 years has been in the tax department at a variety of national firms in several markets providing a strong background in a wide variety of business sizes and industries. He is a technical expert on all matters related to the structuring and taxation of partnerships and limited liability companies. He previously served for on the AICPA's Partnership Taxation Technical Resource Panel.
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Betty J. Boyd, M.A., LL.M.
Office of Chief Counsel
Internal Revenue Service