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 webinar, 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 • The Section 199A qualified business income • Distributions from partnerships |
• Sale of partnership interests, terminations • 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 webinar 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 Internet-Based.
This is a broadcast of our
Partnership Taxation Virtual Boot Camp: An Intensive Four-Day Review of Federal Rules
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 is a broadcast of our
Partnership Taxation Virtual Boot Camp: An Intensive Four-Day Review of Federal Rules
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 is a broadcast of our
Partnership Taxation Virtual Boot Camp: An Intensive Four-Day Review of Federal Rules
Workshop
No results found.
Forum
No results found.