PS: Partnership Terminations (274)

General Description:

Participants will learn how the Tax Cuts and Jobs Act significantly changed and simplified the rules on tax terminations. Even though the rules have been simplified, issues that remain include the tax termination of a two-person partnership, what to do with the expenses of redrafting the operating agreement, and the effect of merging one LLC into another LLC.

Learning Objectives:

After completing this course the participant will be able to:

• Discuss the tax effect of the Tax Cuts and Jobs Act on partnership terminations.
• Describe the tax effect on a partnership where there is death or retirement, sale, gift, ­transfer, contribution, or distribution.
• Distinguish between a state law termination and a tax termination.
• Determine when a two-person partnership terminates and the effect of Rev. Rul. 99-6.
• Describe the difference in a tax termination in 1997, in 2017, and in 2026.
• Apply the varying interest rule under §706(d) to a sale or exchange.
• Discuss the treatment of the expenses in redrafting the operating agreement after a transfer or a redemption.
• Describe the tax effect on the death of a partner and the three possible ways that the interest may be transferred.

Instructors:

Mark A. Vogel is a retired professor and director of the University of Denver Graduate Tax Program, where for 38 years he taught courses in individual, fiduciary, tax accounting, partnership, and corporate taxation. He is the author of Divorce Taxation Guide (John Wiley & Sons) and Individual Taxation (Shepards/McGraw-Hill). He received a J.D. and LL.M. in Taxation from the University of Denver College of Law and an undergraduate accounting degree from the University of Notre Dame. He is also a CPA licensed in Illinois.

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