Revenue Rulings 99-5 and 99-6: Tax Implications of Restructured Partnerships and LLCs
A live 110-minute CPE webinar with interactive Q&A
This webinar will review the components of Revenue Rulings 99-5 and 99-6 and the application of these rulings in frequently encountered scenarios. Our panel of pass-through strategists will focus on the tax implications of these rearrangements and how taxpayers and tax advisers can utilize these rulings to provide tax relief when ownership changes hands.
Outline
- Understanding Rev. Rul. 99-5 and 99-6
- When 99-5 or 99-6 Applies
- Converting a single-member LLC into a partnership
- Converting a partnership into a disregarded entity
- Real world scenarios
- Avoiding common pitfalls
Benefits
The panel will cover these and other critical issues:
- Converting a single-member LLC into a partnership under Revenue Ruling 99-5
- Converting a partnership into a disregarded entity under Revenue Ruling 99-6
- How to ensure acquisition of partnership interests under Rev Rulings and 99-6 qualify for nonrecognition treatment of gains
- The tax implications of Revenue Rulings 99-5 and 99-6 on restructured partnerships
- Common real world scenarios utilizing Rev Rulings 99-5 and 99-6
Faculty
Matthew E. Foreman, Esq., LL.M.
Partner, Co-Chair Taxation Practice Group
Falcon Rappaport & Berkman
Mr. Foreman co-chairs FRB’s Taxation Practice Group and advises businesses on the tax effects of a variety of... | Read More
Mr. Foreman co-chairs FRB’s Taxation Practice Group and advises businesses on the tax effects of a variety of corporate transactions, including taxable and tax-free reorganizations, mergers, sales, and acquisitions. He designs and implements tax-efficient structures for U.S.-based businesses to expand abroad and invest in foreign joint ventures. Mr. Foreman drafts tax memoranda and opinions on a variety of subjects, including tax-free reorganizations, tax-efficient return of capital to owners, Qualified Small Business stock, and various state pass-through entity taxes. He defends clients from audits from the IRS and various state tax agencies, including appealing audit determinations. Mr. Foreman advises clients on a variety of tax issues related to cryptocurrencies, including initial coin offerings (ICOs), taxability of staking and air drops, and the imposition of Sales and Use taxes on the issuance of non-fungible tokens (NFTs). He drafts tax portions of Operating and Shareholder Agreements for businesses in different industries. Mr. Foreman has extensive experience in a variety of SALT issues, especially New York State residency audits and state Sales and Use tax nexus issues post-Wayfair.
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Michelle S. Kabel, Esq.
Attorney
Falcon Rappaport & Berkman
Ms. Kabel is an associate attorney in FRB’s Taxation, Private Client, and Emerging Technologies Groups.... | Read More
Ms. Kabel is an associate attorney in FRB’s Taxation, Private Client, and Emerging Technologies Groups. Her tax planning practice focuses on taxation as it relates to Section 1031 and 1033 exchanges, Qualified Opportunity Zone investments, digital assets, corporate and partnership reorganizations, wealth transfer among families, and private equity fund formation. Ms. Kabel's tax controversy practice includes representing clients before the Internal Revenue Service, the New York State Department of Taxation and Finance, and the New York City Department of Finance; matters include disputes related to income, franchise, and real property transfer taxes.
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Nathan Sosa, CPA, MST
Senior Advisor
Hall CPA
Mr. Sosa is a Senior Tax Advisor at Hall CPA PLLC.
| Read MoreMr. Sosa is a Senior Tax Advisor at Hall CPA PLLC.
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