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.