Tax Treatment of LLC Liquidating Distributions: Income and Deduction Rules, Basis, Tax Distributions, Reporting
Exceptions to General Nonrecognition Rule, Members' Tax Basis in Property, Depreciating Property, Holding Period for Assets, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax professionals an in-depth analysis of the tax treatment of LLC liquidating distributions and key planning techniques for members and partners. The panel will discuss essential factors in determining the taxability of liquidating distributions of cash and property, exceptions to the general nonrecognition rules, the tax basis in property received in liquidation, the holding period for distributed assets, and other key issues regarding the taxation of LLC liquidating distributions.
Outline
- Tax rules applicable to liquidating distributions
- Navigating exceptions to the nonrecognition rules
- Tax issues for liquidating distributions of cash
- Tax challenges for liquidating distributions of property
- Determining tax basis
- Best practices for counsel and taxpayers to minimize tax liability
Benefits
The panel will discuss these and other key issues:
- Tax treatment of the distribution to the LLC and any members
- General nonrecognition rules and exceptions
- Potential tax implications of liquidating distributions of cash and property
- Determining tax basis
- Impact of depreciating property received in a liquidating distribution
- Best practices for counsel and taxpayers to minimize tax liability
Faculty
Robert S. Barnett, JD, MS (Taxation), CPA
Partner
Capell Barnett Matalon & Schoenfeld
Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and... | Read More
Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and partnership law and charitable planning. His experience includes surrogate’s court practice, tax dispute resolution in both federal and state jurisdictions, and tax court representation. Mr. Barnett frequently assists clients in structuring financial transactions and charitable gifts. His articles and lectures encompass a wide variety of topics, including business succession, estate planning, generation-skipping, stock options, effective strategies for removing tax liens, proper utilization of the marital deduction and utilization of partnership elections.
Close
Emily M. Cummins
Senior Associate
Baker Tax Law
Ms. Cummins joins us from Proskauer where she was an associate in the firm’s tax department and a member of its... | Read More
Ms. Cummins joins us from Proskauer where she was an associate in the firm’s tax department and a member of its private funds group. Her work centers on private investment funds and the tax concerns faced by both sponsors and investors in private equity funds. Ms. Cummins has helped to negotiate buy-side and sell-side secondaries transactions; planned and structured continuation funds and other sponsor-led liquidity events; and assisted sponsors with fund structuring concerns involving domestic and international investments. She was selected to be a Protégée for Proskauer’s Women Sponsorship Program, an initiative for high performing midlevel lawyers that champions emerging leaders. Ms. Cummins previously served as co-chair of the Firm’s LGBTQ Affinity Group, and received Proskauer’s Golden Gavel Award for excellence in pro bono work in 2021.
Close
John Harden
Senior Associate
Alston & Bird
Mr. Harden is a senior associate in the Federal & International Tax Group. He has experience providing tax advice... | Read More
Mr. Harden is a senior associate in the Federal & International Tax Group. He has experience providing tax advice across a broad range of transactional matters for private equity clients as well as both public and private strategic clients. Mr. Harden's practice primarily focuses on domestic and cross-border M&A, joint venture, and private transactions, including mergers, auction bid processes, leveraged buyouts, and carve-outs. He represents private equity firms and their portfolio companies, venture capital firms, as well as venture-capital backed and founder- and family-owned businesses across numerous industries. Mr. Harden is recognized by The Best Lawyers in America© on its “Ones to Watch” list in the area of Tax Law.
Close