Taxation of Partnership Distributions and Sales of Partnership Interests (PDS4)

Overview

This program focuses on two parts of Subchapter K, partnership distributions and sales of partnership interests – topics that tax practitioners are often asked about by clients. Tax practitioners are called upon to advise both the partnership which makes distributions and the partners receiving the distributions regarding the tax consequences of these transactions. Additionally, tax practitioners will be deeply involved in decisions regarding the sale and purchase of a partnership interest. These topics are thoroughly covered in this program. The presenters also discuss several types of partnership distributions and the tax rules relating to them, as well as analyze the tax rules relating to the sale of a partnership interest. Tax practitioners will be given an in-depth analysis of these complex topics, so that they can effectively answer their clients’ questions.

Major Topics:

• Types of partnership distributions
• Liquidating partnership distributions
• Basis of property distributed by a partnership
• Special basis adjustments under Section 732(d)
• Abandoned and worthless partnership interests
• Section 751(a) exchange
• Transactions between partners and their partnerships
• Disguised sales
• Section 736(a) and (b) payments

Learning Objectives:

• Be familiar with the complex issues related to partnership distributions and sales
• Advise individual and business clients regarding these practice issues