On June 3-5, Chicago tax head David Polster and partner Sarah Beth Rizzo will participate in PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2024 in Los Angeles.
Mr. Polster will join the session “The Anti-Deferral Rules – Sections 707(a)(2), 704(c)(1)(B), 731(c) and 737,” which will focus on challenging provisions of Subchapter K, including the disguised sale rules of Section 707(a)(2), the antimixing bowl rules of Sections 704(c)(1)(B) and 737, and the marketable securities rules of Section 731(c).
Ms. Rizzo will speak on the panel “Section 704(c): Operations and Implications for Negotiating a Deal and Drafting a Partnership Agreement,” which will explore the determination of a partner’s distributive share by focusing on Section 704(c) and its impact on deal negotiations and the drafting of partnership agreements.
Mr. Polster will join the session “The Anti-Deferral Rules – Sections 707(a)(2), 704(c)(1)(B), 731(c) and 737,” which will focus on challenging provisions of Subchapter K, including the disguised sale rules of Section 707(a)(2), the antimixing bowl rules of Sections 704(c)(1)(B) and 737, and the marketable securities rules of Section 731(c).
Ms. Rizzo will speak on the panel “Section 704(c): Operations and Implications for Negotiating a Deal and Drafting a Partnership Agreement,” which will explore the determination of a partner’s distributive share by focusing on Section 704(c) and its impact on deal negotiations and the drafting of partnership agreements.