The extent to which partnership income taxation invokes an entity or aggregation approach continues to elicit controversy. In a 2017 reviewed decision, Grecian Magnesite Mining v. Commissioner, refused to look inside a partnership to determine the character of gain on sale of the partnership interest. The same judge decided Rawat v. Commissioner, T.C. Memo. 2023-14, limiting the scope of Grecian Magnesite. In July 2024, the Court of Appeals for the District of Columbia Circuit reversed the Tax Court decision, enhancing Grecian Magnesite's entity approach. This webinar will discuss both of these cases and how they affect partnership income taxation along with recent cases that analyze step transaction and economic substance -- the subjects of recent contests.
This webinar will also review a trust’s abilities to complete Code §1031 like-kind exchanges and summarize developments in Code §1202 exclusion of gains from the sale of qualified small business stock. This will include an exploration of capital gain and ordinary income treatment on the sale of partnership interest in light of recent cases. Step transactions and economic substance cases, including a life insurance transfer tax and an income tax case will also be covered.
Learning Objectives:
Thompson Coburn LLP
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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.
Steve Gorin is the former president and an ongoing contributor to Covenant Place’s strategic initiatives. It is a senior affordable housing community with a groundbreaking model for integrated residents with the surrounding community and facilitating holistic services to enrich their lives.
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For approximately 90 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. Whether helping with a tax, estate planning, real estate or employment issue, navigating a complex acquisition or defending a product or service in litigation, we have the knowledge and resources to meet any legal need.
With over 380 attorneys, we have experience in more than 50 areas of the law. Supported by our firm's state-of-the-art technology, lawyers in our Chicago, Dallas, New York, Los Angeles, Southern Illinois, St. Louis and Washington, D.C. offices enjoy a nationwide practice.