Focus on a broad range of distribution issues including disproportionate distributions of “hot” assets and structuring distributions to retiring partners in order to maximize tax benefits for both the retiring partner and the partnership.
Analyze partnership or LLC balance sheets to recognize potential
tax traps associated with distributions and other transfers between
a partnership/LLC and its partner/members
Recognize opportunities to make tax-free exchanges of like-kind
properties through the partnership or LLC
Structure "retirement" distributions to maximize after-tax benefits
to the distributee-partner or LLC member and minimize after-tax costs
to the partnership or LLC
Understand the tax consequences associated with transferring equity
interests to partners or LLC members that are not commensurate with
their capital contributions
Determine the tax consequences associated with the merger of two or more
partnerships/LLCs or the division of a single entity into two or more entities
Prerequisite: Completion of LLC and Partnership Taxation: Beyond the Basics or equivalent knowledge and experience.