Tax practitioners should know and be able to apply the rules that govern partnership distributions and disguised sales conducted through a partnership. Unless the tax professional is able to tell when the disguised-sale rules trump the general partnership distribution rules, the tax practitioner might be led to give wrong advice regarding the taxability or nontaxability of a particular distribution. This program covers the general partnership distribution rules for both current and liquidating distributions, and then explores the circumstances where the so called "disguised sale" rules apply to make an otherwise nontaxable partnership distribution taxable.
Any tax practitioner who wishes to understand the tax rules relating to partnership distributions; any tax practitioner wishing to be updated with how to differentiate between a partnership distribution and a disguised sale.
- Recognize when a partnership distribution is subject to the disguised sale rules
- Understand the tax treatment of cash and non-cash distributions by a partnership to a partner
- Taxation of current and liquidating partnership distributions
- Tax treatment of cash distributions from a partnership to a partner
- Tax treatment of non-cash property distributions by a artnership
- When a partner recognizes gain or loss resulting from a partnership distribution
- Disguised sale rules as they apply to partnership distributions
General background in the taxation of partnership income taxation.