TAX26101. From Contribution to Exit: Partnership Disguised Sales, Distributions, Redemptions & BBA

**INCLUDED IN ALL-ACCESS PASS | IN PERSON ONLY**

Partnership transactions are rarely “just” tax free under §721 and §731—basis adjustments, assumption of liabilities, and §704(c) built-in gains and losses can turn routine contributions, distributions, and redemptions into surprising income and allocation results. In this session, we’ll refresh core mechanics (outside vs. inside basis, §704(b)/§704(c)) and then work through common transaction events: property contributions (including disguised sale risk and liability impacts), property distributions (including §751(b) hot asset and §734(b) considerations), and dry partnership redemptions. We’ll close with practical takeaways under the BBA centralized partnership audit regime, including a discussion of common issues that may arise when a partnership files an administrative adjustment request. You’ll leave the session being able to spot key issues when partners enter and exit partnerships.

Learning Objectives:

• Compute and reconcile a partner’s outside basis, the partnership’s inside basis, and §704(b)/§704(c) capital impacts for common fact patterns—including property contributions, liability shifts, and resulting basis changes.
• Apply the Subchapter K technical rules to identify recognition events and potential traps for the unwary in real-world partnership transactions.
• Describe a partnership’s menu of choices for managing common BBA Administrative Adjustment Request pitfalls and surprises.