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Tax Issues in Transferring LLC and Partnership Interests: Navigating the Complex IRS Rules for Buying, Selling or Redeeming Partnership Interests

October 25, 2018

1:00pm - 2:30pm

Amanda Wilson, a shareholder and member of the firm's Tax Group, will participate on a panel for a CLE/CPE webinar sponsored by Strafford which will provide tax counsel and advisers with an overview of the tax rules that apply to the sale or transfer of an LLC or partnership interest. The panel will discuss common pitfalls and uncertainties in the tax code and outline best practices to structure transactions.

The panel will review these and other priority issues:

  • What are the different tax consequences in choosing between a sale or redemption of a departing partner’s interest?
  • Will a sale or redemption of other partners create a taxable event to the remaining owners?
  • How is the character of gain or loss determined upon a transfer?
  • What are the holding period and basis rules for transfers of partial interests?
  • What is the impact of the Net Investment Income Tax?

For more information and to register, click here.


Amanda

A member of the firm’s tax practice, Amanda Wilson concentrates on federal tax planning and structuring. She represents clients in a wide variety of complex federal tax matters with a particular emphasis on pass-through entities such as partnerships, S corporations and real estate investment trusts. Specifically, Amanda focuses on advising clients on the formation, operation, acquisition and restructuring of such pass-through entities. In addition, she regularly advises clients on the structuring and operation of private equity funds, real estate funds and timber funds. Amanda is the author of the Bloomberg Tax Management Portfolio 718-3rd Edition, Partnerships- Disposition of Partnership Interests or Partnership Business; Partnership Termination.

Amanda regularly works in structuring deals to benefit from tax advantaged structures, including like-kind exchanges, new market tax credits, low income housing tax credits, and qualified opportunity zones. Amanda also has extensive experience in corporate planning and international tax matters, as well as federal tax controversy. Her practice before the Internal Revenue Service (IRS) includes providing advice on audits and appeals, drafting protests and ruling requests, and negotiating settlements.

Prior to joining the firm, Amanda worked for Sutherland Asbill & Brennan LLP (now Eversheds Sutherland), an Am Law 100 firm in the Atlanta office, where she was part of Sutherland’s Tax Practice Group. Amanda has also served as an adjunct professor at Emory University School of Law where she taught Partnership Taxation.

Amanda regularly contributes to the firm’s Taxing Times blog and is a regular panelist on tax webinars hosted by Strafford Publications.

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