September 17, 2013
12:00 – 1:00 p.m.
1.00 MCLE hours
Limited Liability Companies and partnerships come with substantial tax benefits, frequently including the deferral of income or gain on a transaction that would otherwise be taxable. But there a series of transactions between a LLC member/partner and the LLC or partnership which trigger immediate recognition of tax or the permanent disallowance of losses that would otherwise be deductible. Some of these transactions derive from careful planning in the hope of gaining a tax advantage, as in the “disguised sale” of property. Still, many other transactions, such as “guaranteed payments,” are commonplace. This program will provide you with a real-world guide to understanding which transactions between a LLC member/partner and a LLC or partnership will trigger special, adverse tax consequences and discuss planning opportunities to avoid the adverse treatment.
Allen Sparkman, Sparkman Foote, LLP, Colorado