Search results with tag "Structuring redemptions of partnership and"

Structuring Redemptions of Partnership and LLC Interests ...

Jun 14, 2017 · 7 Key Differences in Treatment of Sales vs. Redemptions •Application of Section 751 “Hot Asset” Rules o For redemptions, Section 751 applies to narrower scope of “unrealized receivables” and applies through a deemed sale transaction giving the partnership a step-up in tax basis in those receivables (even if no Section 754

  Partnership, Structuring, Redemption, Structuring redemptions of partnership and