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Lonczak and Lorch Presented at TEI Houston Tax School

Tax Partners Don Lonczak and Steven Lorch spoke on "Opportunities for Monetizing Assets and Tax Credits in Partnership Solution," during the Partnership Planning & Alternative Energy portion of the TEI Houston Tax School. Don and Steven will cover:


  • Debt financed distributions and other methodologies to withdraw cash from an entity taxed as a partnership in a tax deferred manner
  • Disguised sales rules and their potential application to contributions of encumbered assets or distributions of cash, and the exceptions available to avoid sale treatment
  • Mixing bowl and other ‘basis shifting’ rules and their potential application to distributions of property
  • Corporate ‘freezes’ and other transactions that can mitigate ‘double taxation’ but may trigger deemed distributions from a corporate partner if not properly structured
  • ‘Step-up’ deductions and their impact on overall income and interest expense limitations


For more information on the TEI Houston Tax School, please click here.