Skip to content

MENU

Farrell Fritz, P.C. logo
HomeResourcesSubscribeContact

Tax Law for the Closely Held Business

Legal Updates & Commentary for Tax & Estate Planning

Disguised sales

Subscribe to Disguised sales

When a Partner May Not Be Acting As a Partner

By Farrell Fritz P.C. on August 14, 2017
Posted in Federal Tax Issues, Uncategorized

It is not uncommon for a partner to engage in a business transaction with a partnership of which he is a member. If the partner engages in a transaction with his partnership other than in his capacity as a partner, he will be treated as if he were not a member of the partnership with…

Contributing Encumbered Assets: Partnership Disguised Sale Rules

By Farrell Fritz P.C. on June 5, 2017
Posted in Federal Tax Issues

Many of  our posts  this year have considered some of the unique issues that are presented by a partner’s contribution of property to a partnership, including the application of the “disguised sale” rules. Today, we will review one aspect of a recent IRS ruling involving a partnership’s assumption of liabilities in connection with a partner’s…

Disposing of Real Property in a Tax-Advantaged Manner

By Farrell Fritz P.C. on December 19, 2016
Posted in Federal Tax Issues

Do you mean to tell me, Katie Scarlett, . . . that land doesn’t mean anything to you? Why, land is the only thing in the world worth workin’ for, worth fightin’ for, worth dyin’ for, because it’s the only thing that lasts. – Gerald O’Hara, from “Gone With The Wind”

Many of our clients…

Happy Halloween: Partnership “Disguised Sales” (Get It?)

By Farrell Fritz P.C. on October 31, 2016
Posted in Federal Tax Issues

What Is It?

Disguised SaleAssume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X.

What just happened? No, this is not a trick question. Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than…

Stay Connected

LinkedIn RSS

Subscribe By Email

Topics

Archives

Recent Updates

  • How Dealings between Related Parties Doomed a Captive Insurer
  • Corporate Tax Hike on the Horizon: Using Reasonable Compensation to Withdraw Value
  • Leaving New York? Plan for the Taxation of Deferred Compensation
  • The Biden Presidency: How Will Cannabis Business Be Taxed?
  • Statutory Residence for the “Former” New Yorker

Farrell Fritz Blogs

  • All About eDiscovery
  • Federal Government Civil Litigation
  • Long Island Land Use & Zoning
  • NY Business Divorce
  • NY Commercial Division Practice
  • NY Health Law
  • NY Trusts & Estates Litigation
  • NY Venture Hub
Copyright © 2022, Farrell Fritz, P.C. All Rights Reserved.
Privacy PolicyDisclaimer
LinkedIn RSS
Attorney Advertising
Law blog design & platform by LexBlog LexBlog Logo
Farrell Fritz, P.C. (main office): 400 RXR Plaza, Uniondale, NY 11556-3826 (516) 227-0700