On behalf of the Federal Income Tax Committee to the Taxation Section, you're invited:
Partnership Debt Allocations
Date: Thursday, June 1, 2023
Time: Presentation 3:30-4:45 p.m.
Happy Hour/networking 4:45-6:00 p.m.
Cost: Free to Attend
Location: Plante Moran’s Southfield Office, 3000 Town Center, Suite 100, Southfield, MI 48075 (followed by happy hour and networking). Participation via Zoom/Teams available as well.
Please RSVP to Cody Attisha at Cattisha@kerr-russell.com. Please indicate whether you plan on attending remotely or in person. After registering, you will be sent a calendar appointment containing key information for the presentation.
The presentation will address a number of partnership tax issues related to debt allocations, including related party debt allocations under Section 752 and debt allocations for tiered partnerships. It will also cover debt allocations issues related to partnership mergers and acquisition transactions, including debt allocations for purposes of the disguised sale exception under Section 707. Debt allocations sometimes have surprising results so understanding these rules can help prevent unwanted outcomes.
Ivan Hewines, CPA