Subchapter K, which covers partnership taxation, is extensive and always subtly changing. Course materials cover the rules and regulations, including explanations of advanced concepts, needed to effectively serve business and individual partner clients. This course can help participants master the advanced concepts of partnership taxation, enabling them to provide clients with valuable advice and tax planning strategies. Updated with the most recent legislation and IRS guidance affecting partnerships and LLCs, this course will guide participants through the complicated world of advanced partnership and LLC tax law. Some of the many concepts covered in this course include special allocations, liquidating and non-liquidating distributions, property basis calculations under various scenarios, and sales of a partnership interest.
Learning Objectives
- Calculate what a partner will receive in complete liquidation of their partnership interest under Section 704(b) regulations
- Identify the potential economic consequences of special allocations to a partner or LLC member
- Distinguish between “book” allocations required under Section 704(b) and “tax "allocations required under Section 704(c)
- Identify the potential tax consequences when a partner or LLC member makes a contribution of appreciated or depreciated property to the entity
- Distinguish among the various methods prescribed by the regulations to make required special allocations with respect to contributed property
- Distinguish between recourse and nonrecourse liabilities of a partnership or LLC
- Calculate the basis of each property received by a partner or member receiving multiple properties in liquidating and no liquidating distributions from a partnership or LLC
- Recognize which properties will receive a step up or step down in basis when multiple properties are received from a partnership or LLC
- Assess when a partnership or LLC should make a Section 754 election to allow it to increase or decrease the basis of its assets
- Assess the consequences for the buyer associated with the sale of an interest in a partnership or LLC
Major Topics
- Allocation of partnership and LLC income under Section 704(b)
- Allocations with respect to contributed property under Section 704(c)(1)(A)
- Allocation of partnership recourse liabilities under Section 752
- Allocation of partnership nonrecourse liabilities and related deductions under Sections 752 and 704(b)
- Advanced distribution rules
- Adjustments to the basis of partnership or LLC assets
- Sale of an interest in a partnership or LLC
- “Hot” assets and Section 751(a) Section 754 elections,
- Sections 734(b) and 743(b) adjustments, and
- Section 708technical terminations
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