This self-study webinar is for tax professionals who want to explore the most complex partnership rules. In this practical self-study webinar, you'll cover special allocations of income, loss, gain, deductions and distributions through in-depth case studies. You will:
- Gain an in-depth understanding of Section 704(b) regulations
- Review the exceptions to Section 721
- Analyze the allocation of liabilities between partners under Section 752
- Work through examples of special allocations under both Sections 704(b) and 704(c)
- Calculate the asset step-up allowable under Section 754
- Review terminations, liquidations and transfers of partnership interests
To provide tax practitioners who prepare partnership returns or advise clients on partnership issues with in-depth knowledge of complex tax allocation rules, especially under Sections 704(b) and (c). Using case studies, participants will analyze partnership agreements, learn to avoid tax surprises and be able to advise clients to assure correct returns.
- Impact of recent developments on partners and partnerships
- The Section 199A qualified business income deduction
- Section 754 special allocations
- Section 704(b) safe harbor rules
- Minimum gain chargebacks
- Section 704(c) and allocation on contributed property
- Qualified income offsets
- Analysis of partnership agreements to ensure compliance with special allocation rules
- Economic risk rules and liability allocations
- Capital account maintenance
- Effect of admission of new partners on tax allocation
- Deficit restoration agreement
• Identify examples of the individual vs. aggregate partnership taxation concept
• Recognize the implications of a partner’s basis in his partnership interest
• Identify the threshold for recognition as a tax shelter
• Identify partnership items reported to the partners separately
• Identify the tax treatment of a contribution of property in exchange for a partnership interest
• Recognize the applicability of the nonrecognition rules of Section 721(a)
• Recognize circumstances in which a partner will recognize gain upon the contribution of property in exchange for a partnership interest
• Identify the tax implications of a partner’s contribution of services for an interest in a partnership
• Identify those individuals typically personally liable for entity debt
• Identify the characteristics of nonrecourse liabilities
• Identify the tax implications of a partner’s plan to circumvent or avoid an otherwise recourse obligation
• Recognize the rules for the allocation of nonrecourse debt to the partnership partners
• Identify the methodology for allocating nonrecourse debt to partners where the partnership agreement is not respected
• Recognize transactions that will increase a partner’s capital account
• Identify the methodology for the allocation of nonrecourse debt to the partnership partners
• Identify the circumstances under which the contribution of property rules under Section 704(c) will not apply
• Identify the acceptable allocation methodologies under Section 704(c)
• Recognize the circumstances under which the IRS can re-characterize a partnership transaction under the partnership anti-abuse regulations
• Recognize a partner’s basis in property received from a partnership in a current property distribution
• Recognize a partner’s basis in property received from a partnership in a liquidating property distribution
• Identify the tax implications of partnership guaranteed payments
• Identify the partner’s tax basis in property received from a partnership in a current property distribution
• Recognize the general purpose of the Section 754 election
• Recognize the mechanics of the Section 754 step up in basis