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Course/Product Description
Title:

Partnership Debt Allocations And New IRS Regulations: Minimizing Tax Consequences Meeting Challenges of IRS Crackdown on Leveraged Partnerships, Mitigating Liabilities Under the Disguised Sales Rules

SKU:WC-1026556
Date / Time: Recorded
Format: Webinar
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Description:

This CLE/CPE webinar will provide tax advisers with a thorough and practical guide to the challenges of allocating recourse and nonrecourse partnership debt, including a critical review of the Treasury regulations issued under IRC §§707 and 752. These regulations significantly changed rules related to the allocation of partnership liabilities and partnership “disguised sales.” The regulations cut back sharply on deferral opportunities using “leveraged partnerships” and eliminate gain deferral through the use of “bottom guarantee” structures.

The IRS issued a sweeping package of regulations which changed the rules governing the allocation of partnership liabilities, effective Oct. 2016. The new regulations cut back on deferral opportunities using “leveraged partnerships,” and eliminate gain deferral through the use of “bottom guarantee” structures. These new rules immediately and dramatically affected virtually all partnerships with debt as part of their funding structures.

Under the revised rules, bottom-dollar obligations defined in the regulation will no longer be considered recourse liabilities but will instead be treated as nonrecourse debt and allocated to all partners within the partnership. These changes will result in a scenario where a partner who serves as a guarantor for a loan to the partnership can be at economic risk for the amount of the guaranty, while not receiving any recourse debt allocation for the amount at risk.

While the U.S. Treasury reported to the President in Oct. 2017, proposing substantial revisions to certain of its regulations issued after Jan. 1, 2016, the report did not recommend significant changes to the proposed and temporary regulations on bottom-dollar guarantees.

While the focus of the initial regulations is related to debt structures as an indicator of a disguised sale, the additional rules are likely to dramatically impair the ability of partnerships to utilize debt allocation structures to attract investors. Tax advisers must react quickly to ensure their clients’ partnership structures are compliant with the new rules.

Listen as our experienced panel provides a critical first look at the new partnership debt regulations and offers practical guidance on protecting client partnerships from costly tax consequences.

Outline

  • Background on Sections 707 and 752
  • Overview of new Section 752 regulations
    • “Bottom dollar” guarantees and similar arrangements
    • Proposed regulations’ anti-abuse rule
    • Effective date/transitional rules
  • Overview of new Section 707 regulations
    • Treatment of all liabilities as nonrecourse
    • Effective date/transitional rules
  • Practical impact of new rules
    • Impact on common business transactions such as “leveraged partnerships” and “asset drop-down transactions”
    • Alternative planning techniques
Benefits

This panel will review these and other key issues:
  • Distinguishing recourse from nonrecourse partnership debt
  • The impact of the new regulations on common business transactions, such as leveraged partnerships and asset “drop-down” transactions
  • What tax advisers must do now to prepare partnership clients for the new regulations
How To Access Course And Materials

Handout materials and the phone number for live presentations are made available to you one day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CDs will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.

Continuing Education Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. To obtain CPE credit, attendees must participate in the live event (recorded versions do not qualify for credit), return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Strafford will mail a certificate of credit within approximately two weeks of receiving your completed Official Record of Attendance, provided all required conditions have been satisfied.

Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.

Cannot Attend The Live Presentation?

This presentation is also available in a recorded format, in On-Demand Or CD versions, as shown in the pricing options below.

About Webcasts / Audio Conferences / Podcasts:

Webcasts, audio conferences, and podcasts are presentations that you attend via the Internet, phone, or mobile device at a specified date and time for "live" versions, or at your convenience for "recorded" and "On-Demand" versions.

The live versions are interactive, meaning that participants can ask questions in real time, plus are a very cost-effective form of training because 1) you receive fast, convenient learning without any out-of-office time; 2) you can invite as many colleagues as you'd like to listen in on a single phone line; 3) you incur no travel expenses; and 4) you and your colleagues are back at work immediately after the session ends!

And though with recorded versions you do lose the ability to ask questions, you gain the ability to hear the presentation numerous times and to share it with others in your office.

Handout materials and the phone number for live presentations are made available to you prior to the event via email from the presenter and from the "MyAccount" link on the menu bar. Copies of the presentations are included with recorded versions.

About The Provider: Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417 or by visiting their website.

Strafford webinars and teleconferences offer an excellent opportunity to train your entire staff—with no lost travel time or expenses. They are extremely cost-effective—allowing an unlimited number of people at your location to listen from a single line at no additional charge.

Each live seminar features presentations by a panel of nationally recognized authorities, followed by an interactive Q&A session. Presentation materials can be viewed online or printed out. Audio can be accessed via the web or a telephone.
More Info: Contact Us For More Information
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