The Heat is On: Understanding IRC § 751
When a partner starts the negotiation process to sale their interest, they may not consider the tax treatment of Hot Assets. These Hot Assets are business assets, that if sold have the potential to create ordinary income.
This course will provide a useful overview of techniques to assist the tax professional in
assisting their clients who sell partnership interests. Ensure that we do not, as tax advisors, assume that equally situated taxpayers will be treated similarly by the Tax Code.
Learning Objectives:
- Distinguish the categories of Hot Assets
- Analyze the three (3) steps necessary to be calculated on every calculation regarding IRC
Section 751
- Extrapolate issues skulking in the tax code that can surface and cause tax pain to
our clients
- Interpret why similar types of entities do not always result with the same tax results
- Discuss Form 8308
- Provide detail examples to demonstrate how Section 751 applies to the sale of partners' interests
1 IRS CE/1 NASBA CPE*
"Our best deal is always to become a monthly subscriber"
*Self-Study recording not available for NASBA CPE credit.
Allan J. "A.J." Reynolds
,
EA
A.J. is an enrolled agent (EA) with over thirty years of experience encompassing various areas of taxation. Though his practice centers on Individual, Business, and Estate Tax preparation, A.J. specializes in IRS Audits, Appeals, Collections, Innocent Spouse, Independent Contractor vs. Employee Issues, and Civil Tax Fraud Representations. As diverse as his specializations, A.J.’s clientele, too, ranges from average workers to Fortune 500 executives.Based in Sioux City, Iowa, A.J. nevertheless brings his everyday “in the trenches” experience to seminars nationally and internationally to assist attendees with real issues affecting tax professionals. A.J. has spoken Basics + Beyond Income Tax Seminars and Webinars, NATP National Conference and Webinars, NAEA Webinars, NTI Resort Conferences, and Iowa State University Webinars and Annual Tax Seminars.A.J. started his tax career with a national CPA firm in San Diego, CA after proudly serving for five years in the United States Navy onboard the Guided Missile Destroyer USS Callaghan. During his time on the destroyer, A.J. and crew members were awarded the Navy Expeditionary Medal for their work in the Straits of Hormuz off the coast of Iran.Outside of his tax practice, he is a member of the Diocese of Sioux City Priests’ Pension & Welfare Board and the Investment Advisory Board for the Diocese. When not working, his time is spent in various activities, including traveling with his wife and their two children.
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