The purpose of this course is to provide an in-depth discussion of selected advanced-level issues affecting LLCs and LLPs.
Learning Objectives
- Identify when distributions are taxable, including disguised sales and the tax on pre-contribution gain
- Discuss the tax consequences of a liquidation of a partner’s interest
- Describe the options when a partnership terminates or continues following an acquisition or merger
- Explain the tax consequences of a sale of an interest and distinguish such consequences from the tax consequences when a partnership or LLC is acquired or merges into another LLC or partnership
Major Topics
- When are distributions taxable?
- Miscellaneous issues, including the critical difference between §736(a) and §736(b) payments
- Sales of an LLC interest -- holding period and hot asset issues
