The Seventh Circuit issued its long-awaited decision in Hoops, LP v. Commissioner, Docket No. 22-2012 (7th Cir. Aug. 10, 2023), in which it held that a partnership could not deduct deferred compensation due under a non-qualified deferred compensation plan to two NBA players when the deferred compensation liability was assumed by the purchaser of the Memphis Grizzlies NBA basketball team. This result means that the seller’s amount realized on the sale includes the amount of the liability assumption, yet the seller is not entitled to a deduction for the deferred compensation at the time of the sale. At this Fall’s Forum programs, we will be discussing this important case and how to structure a sale of a business where the buyer is assuming a non-qualified deferred compensation liability to avoid this whipsaw.
Registration Is In Full Swing For Our 2023 Tax Forum programs.
Capacity is limited for our in-person programs in Las Vegas and Orlando. Register Now before registrations and rooms fill up.
For those of your who prefer the comfort of your own home/office, please join us for any of the 14 virtual Forum and Fundamentals programs… the first of which kicks-off in two months on October 17th.
We look forward to seeing you… either in person or remotely… very soon!
In the meantime, we are always happy to address your questions related to any passthrough or closely held business matter that comes up in your practice. Please do not hesitate to call us at 800-286-4760 or email either of us.
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