Partnership Taxation Boot Camp: An Intensive Four-Day Review of Federal Rules

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Get the confidence to handle taxation for partnerships in this four-day certification program!

Partnership Taxation Boot Camp: An Intensive Four-Day Review of Federal Rules

CPE Credit: 32 Hours

Price: $2,500.00

NASBA Field of Study: Taxes

 

Overview

The tax rules for partnerships are complex regarding the allocation of gain, loss, depreciation, recourse and non-recourse liabilities, contributed property and other tax attributes. The need for tax professionals with specialized training to understand the opportunities and pitfalls that these rules present has never been greater.

In this in-depth program, you will work through numerous examples, learn how to fill out critical forms and use real-world case studies to discover how you can apply key concepts to your clients’ benefit. You’ll acquire the knowledge and confidence you need to effectively handle and provide advice on partnership issues.
 

AGENDA HIGHLIGHTS


•  Introduction to partnerships

•  Operational issues

•  Formation of the partnership

•  Basis in the partnership interest

•  Disguised sales rules

•  Section 751 (“Hot Assets”)

•  Taxable income: a look at the K-1

•  Partner’s distributive share of partnership items

•  Distributions from partnerships
 

•  Sale of partnership interests, terminations
   and liquidations

•  Section 754 optional basis adjustments

•  Passive loss rules

•  Tax planning discussions

•  Investment partnerships

•  IRS case study

•  Real property trades or businesses

LEARNING OBJECTIVE  Through the use of case studies, this Boot Camp will supply you with practical ways to implement partnership
tax requirements.

PREREQUISITE  Basic knowledge of federal taxation.    ADVANCE PREPARATION  None.    PROGRAM LEVEL  Intermediate.
NASBA FIELD OF STUDY  Taxes.    DELIVERY METHOD  Group-Live.

 

This program is also available via live webcast
Partnership Taxation Boot Camp: An Intensive Four-Day Review of Federal Rules Webcast

Agenda

AGENDA


Times: 8:30 AM - 5:00 PM
 

DAY ONE

INTRODUCTION TO PARTNERSHIPS
Partnership entity
Key aspects of partnership law and tax implications
Review types of partnerships and Limited Liability Companies/Partnerships
Electing out of Subchapter K
Check-the-box regulations

OPERATIONAL ISSUES
Tax year and accounting methods
Items required to be stated separately
Partnership and partner elections
Other operational issues

FORMATION OF THE PARTNERSHIP
Introduction
Contributions of property and cash, no gain or loss
Contribution of property if fair market value and basis differ under Section 704(c) rules
Contribution of services in exchange for a partnership interest

BASIS IN THE PARTNERSHIP INTEREST
Introduction
Inside and outside basis, basis vs. capital accounts
Determination of the partner’s basis in the partnership interest
Definition of liability for partnership purposes and allocation among partners
Review examples/case study
IRS court case discussion
 

DAY TWO

DISGUISED SALES RULES
Introduction—potential inequity of the tax rules
Disguised sales rules and exceptions described
Liabilities and disguised sales rules, tax return disclosure
Property distributions that follow contributions of appreciated property

IDENTIFICATION & TREATMENT OF SECTION 751 HOT ASSETS
Application of the rules, definition of hot assets
Tax treatment in section 751 transaction and reporting requirements

PARTNERSHIP TAXABLE INCOME: A LOOK AT THE K-1
Partnership as a pass-through entity
At-risk rules under IRC 465
Partnership and LLC issues and K-1s
Review Form 1065, Schedule K and Schedule K-1 and instructions

PARTNER’S DISTRIBUTIVE SHARE OF PARTNERSHIP ITEMS
Allocations under partnership agreement must have substantial economic effect, section 704(b)
Review of problem areas
Anti-Abuse Regulations 1.701-2(b)
Elections by partnerships
Case study
IRS Tax Court Case discussion
 

DAY THREE

DISTRIBUTIONS FROM PARTNERSHIPS
Overview of distributions
Taxation of current distributions, cash, securities, and/or property
Taxation of liquidating distributions

SALE OF PARTNERSHIP INTERESTS, TERMINATIONS & LIQUIDATIONS
Purchase, sale or redemption of partnership interests
Retiring partner’s or successor’s share
Termination of partnership
Distributions in liquidation of a partnership interest

SECTION 754 OPTIONAL BASIS ADJUSTMENTS (STEP UP) UPON SALE OR TRANSFER
Theory for Optional Basis Adjustment
Section 754 Election
Mandatory basis adjustments under Section 743 and Section 734

PASSIVE LOSS RULES
Background
Definition of Activity and Material Participation

TAX PLANNING DISCUSSIONS
 

DAY FOUR

REVIEW THROUGH PROBLEM SOLVING
Prepare simple Form 1065, K-1
Complete Partner Basis Worksheet

INVESTMENT PARTNERSHIPS
Discussion and problem solving

IRS CASE STUDY

REAL PROPERTY TRADES OR BUSINESSES
• Formation and basis of a real estate partnership
Operating income and expenses
Deductibility of losses, passive losses
Distributions from partnerships, taxability
Like-kind exchanges, installment sales, lease transactions

CASE STUDY/IRS TAX CASE REVIEW

CLIENT ENGAGEMENT LETTER DISCUSSION/SCOPE

WRAP-UP

 

This program is also available via live webcast
Partnership Taxation Boot Camp: An Intensive Four-Day Review of Federal Rules Webcast

 

Speakers

PROGRAM SPEAKERS


W. Stewart Connard, CPA, retired from the Internal Revenue Service in 2009 after 36 years of service. From 1999 to 2009, he was a Partnership Technical Adviser in the Pre-Filing & Technical Guidance section of the Large and Mid-Size Business (LMSB) Unit. As a Partnership Technical Adviser, he assisted revenue agents in examining large public and private corporations on complex partnership issues and tax shelter transactions. From 1973 to 1999, he was an Internal Revenue Agent in the former IRS Baltimore District. Throughout his career, he has taught numerous tax courses for the Internal Revenue Service, state tax agencies and the DC Institute of CPAs. He is a graduate of Shippensburg University in Shippensburg, PA.
 

Deborah A. Phillips, MST, CPA, is a retired Senior Manager of the Internal Revenue Service. She has extensive accounting and taxation knowledge of individual, corporate and partnership federal tax returns. Previously, Ms. Phillips was the Operations Executive Assistant to the Deputy Commission International, the Technical Executive Assistant to the Director of PFTG, a Territory Manager in the retail, food and pharmaceuticals industries, a Team Manager in the heavy manufacturing industry, as well as the IRC Section 263A Technical Advisor. She taught graduate and undergraduate courses in accounting and taxation as an adjunct faculty member at Delaware State University, Wilmington College and Goldey-Beacom College. She has been a seminar presenter for over 18 years.

 

This program is also available via live webcast
Partnership Taxation Boot Camp: An Intensive Four-Day Review of Federal Rules Webcast

 

Workshop

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Location

Boston Marriott Newton
2345 Commonwealth Avenue
Newton, MA 02466
(617) 969-1000

 

Convene-Tysons Corner
1800 Tysons Boulevard
McLean, VA 22102
(703) 552-4443

 

Palmer House Hilton
17 East Monroe Street
Chicago, IL 60603
(312) 726-7500

 

APA Woodbridge
120 Wood Avenue South
Iselin, NJ 08830
(732) 494-6200

 

InterContinental San Francisco
888 Howard Street
San Francisco, CA 94103
(888) 811-4273

 

New York-New York Hotel & Casino
3790 Las Vegas Boulevard South
Las Vegas, NV 89109
(800) 689-1797

 

Convene Midtown West
810 7th Avenue
SL Green Realty Corp. Building, 23rd Floor
New York, NY 10019
(888) 730-7307

 

Hilton DFW Lakes
1800 Highway 26 East
Grapevine, TX 76051
(817) 481-8444

 

Courtyard Marriott City Avenue
4100 Presidential Boulevard
Philadelphia, PA 19131
(215) 477-0200

 

This program is also available via live webcast
Partnership Taxation Boot Camp: An Intensive Four-Day Review of Federal Rules Webcast