Description
Gain a better understanding of the rules and issues surrounding corporate and partnership liquidations.Join our presentation discussing the tax consideration pertinent to business liquidation. The topic will cover the tax treatment upon liquidation to corporations and partnership and each of their shareholders and partners. The presentation will provide an analysis of the current law concerning the tax treatment of these business entities, an overview of when a liquidation occurs, applicable reporting requirements, practical tips, and available planning opportunities.
Date: 2023-04-26 Start Time: End Time:
Learning Objectives
Overview
• Speaker Introduction and Background
• Background on Topic and the Importance of Understanding Tax Consequences
• Overview of Topic
• Entities Covered
• What Is a Liquidation and the Different Types
• Practical Approach
Corporation
• Tax Treatment to Shareholders
• Corporate Shareholder
• Non-Corporate Shareholder
• Gain/Loss
• Tax Consequences to Liquidating Organization
• Treatment Liabilities
• Basis Reduction
• Assumption of Liabilities
• Cod Income and Applicable Exemptions (Bankruptcy)
• Consolidation Group Considerations
• S Corporation Considerations
Partnership
• Liquidating Distributions
• Liquidating Distribution to Partner
• Partnership Termination
• Non Recognition of Gain/Loss
• Series of Distributions
• Liability Relief
• Recapture and 1250 Gain
• Basis of Distributed Property
• Allocation of Basis
• Inside Basis
• Suspended Losses
• Closing Tax Year
Planning Opportunities
• Consolidated Filings; Treas. Reg. §1.1052-13(g)
• Availability of Tax Elections
• Practical Tips to Minimize Tax Liability
Procedural Requirements
• Corporation Must Adopt a Plan of Liquidation
• Filing of Form 996
• Reporting Requirements
Conclusion
Questions and Answers
AIPB ,CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Peter Farrell-Baker Botts L.L.P., Stephen Weinstein – Baker Botts L.L.P.
