This program is an in-depth analysis of the Section 754 election and the two adjustments associated with the election under Section 743(b) and Section 734(b). The 754 election is a highly technical provision that provides great tax benefits to the owners of the partnership, and particularly in the case of Section 743(b), a new partner. This course covers the most common questions encountered by practitioners in their daily practices. The program includes a number of examples that provide insights into the mechanics of the two adjustments that follow upon a Section 754 election.
Learning Objectives
- Be familiar with the practical issues surrounding Section 754 and its application
- Effectively advise clients on these complex issues
Major Topics
- How does a partner compute his or her basis in a partnership?
- What is the difference between a partner’s inside and outside basis?
- What is the difference between a partner’s capital account and partner’s outside basis?
- How does Section 732(d) impact the buyer of a partnership interest?
- How does a partnership report a Section 754 election on the partnership’s tax return?
- How does a partnership make a Section 754 election?
- How does a partnership make a Section 743(b) adjustment?
- How does a partnership make a Section 734(b) adjustment?
- How is a Section 743(b) adjustment or Section 734(b) adjustment allocated to the assets of a partnership?
- How is a Section 743(b) adjustment allocated within the class of ordinary income property and capital gain property?
