When a partner starts the negotiation process to sale their interest they may not consider the tax treatment of Hot Assets. These Hot Assets are business assets, that if sold have the potential to create ordinary income.
This course will provide a useful overview of techniques to assist the tax professional in assisting their clients who sell partnership interests.
Ensure that we do not, as tax advisors, assume that equally situated taxpayers will be treated similarly by the Tax Code.
Learning Objectives
Upon completing this course, participants will be able to:
Distinguish the categories of Hot Assets
Analyze the three (3) steps necessary to be calculated on every calculation regarding IRC Section 751
Extrapolate issues skulking in the tax code that can surface and cause tax pain to our clients
Interpret why similar types of entities do not always result with the same tax results
Discuss Form 8308
Provide detail examples to demonstrate how Section 751 applies to the sale of partners' interest
Major Topics
Categories of Hot Assets
Potential Issues
