Taxation of Partnership Sales, Distributions and Liquidations (TSDL)

Partnership tax is one of the most difficult areas tax practitioners must understand to help their business clients. Partnerships commonly make distributions to owners, are sold or are liquidated. Tax practitioners should understand the rules that apply in these circumstances to minimize their clients’ tax liability and ensure their clients are in compliance with applicable tax rules. This program explores the often-complex tax rules dealing with these three commonly encountered partnership events.

• Taxability and character of gain or loss when an interest in a partnership is sold
• Consequences of a Section 754 election in the context of sale of a partnership interest
• Taxability of cash and property distributions made by a partnership to a partner
• When a loss can be recognized on a partnership distribution
• Differences between liquidating and nonliquidating partnership distributions
• Tax consequences of a partnership liquidating distribution
• Calculating a partner’s basis to determine if a partner has a gain or loss on distribution
• Impact of Section 704(c) on contribution of appreciated or depreciated property to a partnership