PS: Transactions Between Partners and Partnership

General Description:

The Partnership Series is taught on a basic level for new tax professionals. The practitioner will gain an understanding of the rules that apply when a partner/member lends, leases, or sells property to the partnership/LLC.

Learning Objective:

After completing this course the participant will be able to:

• Identify when a partner is dealing with the partnership in a non-partner capacity: §707(a) payment.
• Identify when a partner is dealing with the partnership in a capacity as a partner: §707(c) payment; and explain the difference between an entry on a Schedule K-1 Line 4(a) and Line 4(b).
• Explain the disguised sale rules under §707(a)(2)(B) and a disguised payment for services under §707(a)(2)(A).
• Differentiate between a partner performing services in a capacity as a partner or as a non-partner.
• Determine the tax effect of a sale of property to or from a partnership, including disallowance of losses and recharacterizing the gain as ordinary income.
• Apply §267(e) to payments from a partnership to a partner.
• Determine how to treat payments for use of capital.
• Distinguish between a regular guaranteed payment and a guaranteed minimum.
• Explain the concept of land banking.
• Identify the tax problems that are created when an individual receives a carried interest as a fee for agreeing to manage the LLC and the effect of §1061.
• Explain the self-charged interest rules and the self-rental rules.

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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