TAX26101. From Contribution to Exit: Disguised Sales in Partnerships, Distributions, Redemptions, and the BBA

**INCLUDED IN ALL-ACCESS PASS | IN PERSON ONLY | PRE-REGISTRATION IS REQUIRED**

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 and §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 common issues that may arise when a partnership files an administrative adjustment request. You’ll leave able to spot key issues when partners enter and exit partnerships.

Learning Objectives:

• Calculate a partner’s outside basis, the partnership’s inside basis, and capital account impacts under §704(b) and §704(c) for common fact patterns, including property contributions, liability shifts, and resulting basis changes.
• Identify recognition events and common traps in real-world partnership contributions, distributions, and redemptions, including disguised sales, §751(b), and §734(b) adjustments.
• Select approaches for managing common BBA administrative adjustment request pitfalls, including issues that may arise during filing.