Overview
Disguised sales rules can be tricky and the tax consequences can be costly. Any time a partner transfers property or another asset into the partnership, it opens the possibility of running afoul of the IRS Code’s disguised sales rules.
In this self-study webinar, you will learn how to recognize a disguised sale when you encounter one, the elements of a disguised sale, the impact of liabilities on disguised sales and how to avoid disguised sales and their resulting taxes.
AGENDA HIGHLIGHTS
• Introduction: potential inequity of the tax rules
• Disguised sales rules and exceptions described
• Liabilities and disguised sales rules, tax return disclosure
• Property distributions that follow contributions of appreciated property
LEARNING OBJECTIVE To teach tax professionals how to recognize a disguised sale, the elements of a disguised sale, the impact
of liabilities on disguised sales and how to avoid disguised sales and their resulting taxes.
PREREQUISITE Basic knowledge of federal taxation. ADVANCE PREPARATION None. PROGRAM LEVEL Intermediate.
NASBA FIELD OF STUDY Taxes. DELIVERY METHOD Self-Study.
Speakers
SPEAKER
W. Stewart Connard, CPA
Detailed Learning Objectives
• Identify the tax implications of the contribution of property to a partnership in exchange for a partnership interest
• Identify the criteria for disguised sale treatment
• Recognize the tax implications of a disguised sale
• Recognize the characteristic and tax implications of guaranteed payments
• Recognize the rules for allocating liabilities under Section 752
