Redemptions of Partnership Interests: Sections 736(b) vs. 736(a)
Installment Sales, Hot Assets, OBBBA Modifications to SALT Caps
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss redemptions of partnership interests for tax advisers working with partnerships and LLCs. Our authoritative panel will explain the tax effects of these dispositions on the partner, the remaining partners, and the partnership, including the application of ordinary versus capital gains tax rates, installment sales, and new considerations resulting from recent legislation including the One Big Beautiful Bill Act (OBBBA).
Outline
- Redeeming partnership interests
- IRC Sections 736(b) and 736(a)
- Goodwill
- Section 754 elections
- Impact of recent legislation
- Partnership audit rules
- OBBBA and state PTE taxation regimes
- Other
- Installment sales
- Section 751 property
- Notable cases and rulings
Benefits
The panel will cover these and other critical issues:
- Tax consequences of redemptions on the exiting partner and the partnership
- Calculating the tax on the redemption when the partnership holds hot assets
- Structuring redemptions to withstand IRS challenges
- Making a Section 754 election when a partner's interest is redeemed
- The effect of SALT caps and the OBBBA on redemptions
Faculty
Joseph C. Mandarino
Partner
Smith Gambrell & Russell
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of... | Read More
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino’s practice also includes representation in tax controversy work. He writes and speaks extensively on a wide range of business, tax and finance topics.
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Nathan Sosa, CPA, MST
Senior Advisor
Hall CPA
Mr. Sosa, CPA, MST, is the Manager of the National Tax Department and the Audit Defense Division at Hall CPA. He... | Read More
Mr. Sosa, CPA, MST, is the Manager of the National Tax Department and the Audit Defense Division at Hall CPA. He specializes in consulting on technical tax issues, including Qualified Opportunity Zone structuring, partnership matters, and Section 469 considerations within the real estate industry and small business sector. Mr. Sosa also provides professional guidance to tax professionals and accountants, offering insights into complex tax strategies and compliance matters.
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