The Heat is On: Understanding IRC § 751

When a partner starts the negotiation process to sale their interest, they may not consider the tax treatment of Hot Assets. These Hot Assets are business assets, that if sold have the potential to create ordinary income.

This course will provide a useful overview of techniques to assist the tax professional in
assisting their clients who sell partnership interests. Ensure that we do not, as tax advisors, assume that equally situated taxpayers will be treated similarly by the Tax Code.

Learning Objectives:

- Distinguish the categories of Hot Assets
- Analyze the three (3) steps necessary to be calculated on every calculation regarding IRC
Section 751
- Extrapolate issues skulking in the tax code that can surface and cause tax pain to
our clients
- Interpret why similar types of entities do not always result with the same tax results
- Discuss Form 8308
- Provide detail examples to demonstrate how Section 751 applies to the sale of partners' interests

1 IRS CE/1 NASBA CPE*

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*Self-Study recording not available for NASBA CPE credit.