Andy Immerman presented during this teleseminar hosted by Strafford. IRC Section 707 focuses on partnership transactions in which a member-partner performs services, transfers property, engages in sales or exchanges of property, or receives guaranteed payments for use of capital. Advisers must analyze transactions to determine which events are taxable by examining whether the partner is acting outside the role as partner. This analysis is complicated by disguised sales rules, as well as the evolving interpretations by the IRS and courts of the circumstances that warrant federal taxation. Practitioners face the challenge of interpreting Section 707 and providing clients with advice in an area rife with ambiguity to those unaware of material terms and interpretations.
The authoritative panel of this teleseminar explained the key points of Section 707 and explored the circumstances deemed by the IRS and courts as disguised sales and abusive situations triggering taxable events.
March 6, 2012