Surgent's Limited Liability Companies: Losses, Liquidations, Terminations,Continuations, and Sales Download

Overview

The purpose of this course is to provide an in-depth discussion of selected advanced-level issues affecting LLCs and LLPs.

Prerequisites

A beginning course in LLCs/partnerships; experience with LLC/partnership clients

Objectives

• Identify when distributions are taxable, including disguised sales and the tax on pre-contribution gain
• Discuss the tax consequences of a liquidation of a partner’s interest
• Describe the options when a partnership terminates or continues following an acquisition or merger 
• Explain the tax consequences of a sale of an interest and distinguish such consequences from the tax consequences when a partnership or LLC is acquired or merges into another LLC or partnership
• All four of the above bullet points offer options; the practitioner must understand the various tax consequences of the options

Highlights

• When are distributions taxable?
• Miscellaneous issues, including the critical difference between §736(a) and §736(b) payments
• Sales of an LLC interest -- holding period and hot asset issues
• Tax Cuts and Jobs Act of 2017 partnership and LLC provisions, including latest updates on §199A as it shakes itself out