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Preserving Income Tax Benefits from Estate Tax Audits; S Corporation Sales; Partnership Redemptions


Drawn from Steve Gorin’s 4th quarter 2022 newsletter, this course discusses preserving income tax benefits from estate tax audits and selected issues relating to S corporation sales and partnership redemptions. 

Preserving income tax benefits from estate tax audits discusses coordinating estate tax and income tax statute of limitations and includes a recent case in which the taxpayer failed to take the steps necessary to preserve rights to income tax benefits and therefore lost them. 

S corporation sale topics start with a brief of overview of recent IRS relief from various mistakes to avoid needing to get a private letter ruling before a sale. Next we review briefly tools to avoid gain on the sale of a business, before addressing coordinating this with the buyer’s desire to get a basis step-up in the business’ assets. We briefly compare state income issues on the sale of business interests with the sale of business assets, including recent cases. Next we review the deferred sales trust, including relatively recent Chief Counsel Advice regarding that tool. 

Finally, we discuss partnership redemptions, reviewing the flexibility afforded them and comparing them with installment sales. We conclude with a surprising case where exiting partnerships had to recognize ordinary income when they exited wrongfully and took clients with them. 

The live presentation of this webinar was approved for 1.5 hours of general CLE credit in California, Illinois, and Texas; 1.8 hours of general CLE credit in Missouri; and 1.5 hours of professional practice CLE credit in New York. Please visit the CLE Overview page to see how the CLE credit for this recorded webinar can be applied in CA, IL, MO, NY, & TX. 

If you are interested in receiving CA, IL, MO, NY, or TX CLE credit for watching the recorded presentation, you must register for the program by clicking here. If you are not interested in receiving CLE credit, you can watch the presentation by clicking the play button on the video.

Participants will only be emailed a Certificate of Attendance if the webinar is viewed in its entirety. If you were unable to view the webinar in its entirety, please contact webinarinquiries@thompsoncoburn.com to see if you are eligible to receive partial credit. 

If you do not receive your Certificate of Completion, please e-mail webinarinquiries@thompsoncoburn.com

Steve Gorin

For technical materials supporting the slides, please see Steve's newsletter.

Originally Presented:
January 31, 2023