Date: November 22nd 2024

Time: 1pmET | 12pm CT | 11am MT | 10am PT

Duration: 120Minutes

Partnership income taxation continues to be a hotbed of controversy, particularly when it comes to whether an entity or aggregation approach should be used. The 2017 decision in *Grecian Magnesite Mining v. Commissioner* made waves by refusing to look inside a partnership to determine the character of gain on the sale of a partnership interest. However, the 2023 case *Rawat v. Commissioner* (T.C. Memo. 2023-14) narrowed the scope of *Grecian Magnesite*. In a significant development, the Court of Appeals for the District of Columbia Circuit reversed the Tax Court’s decision in July 2024, reinforcing the entity approach established by *Grecian Magnesite*.

This webinar will dive into both of these cases, examining their impact on partnership income taxation. Additionally, we will explore recent cases addressing step transactions and economic substance, which have become critical areas of focus in tax litigation.

The session will also cover trusts and their ability to complete like-kind exchanges under Code §1031, along with the latest developments regarding the exclusion of gains from the sale of qualified small business stock under Code §1202. We’ll discuss the treatment of capital gains and ordinary income on the sale of partnership interests in light of these new rulings, as well as analyze the impact of recent step transaction and economic substance cases, including those related to life insurance transfer taxes and income tax issues.

Learning Objectives:

Understand the tax treatment of capital gains and ordinary income on the sale of partnership interests
Identify recent case law analyzing step transactions and economic substance
Evaluate a trust’s ability to complete like-kind exchanges under Code §1031
Review recent developments in the exclusion of gains from the sale of qualified small business stock under Code §1202

Credits and Other information:

• Recommended CPE credit – 2.0
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 2 Hours

Who Will Benefit:

• CPA
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
• Financial planners

About Our Speaker

Steve Gorin, CGMA, CPA, J.D.
Steve has drafted trusts and a full range of estate planning documents for clients to help grow, preserve, and transmit their family wealth. He has also prepared organizational documents for limited liability companies, corporations, and partnerships to implement their owners’ wishes regarding current and future control and transmission, including bringing in new owners and facilitating exit strategies.

Steve enjoys helping clients structure their affairs to achieve their personal, business, and financial goals while reducing the drag that taxes imposed on them. His firm provides full service to businesses; however, he also acts as counsel on specialized matters while cooperating and facilitating the continued involvement of an existing legal, accounting, and financial services team. Steve maintains his CPA license but prefers to refer income tax returns to practicing CPAs.