Partnership Taxation: Level II Webinar Self-Study Webinar

To give tax and other financial professionals the special knowledge and skills to deal with advanced partnership tax topics and special problems ranging from allocations to complex transactions between the partner and partnership. Participants will analyze the regulations by working through actual examples and reviewing partnership agreements.

DETAILED LEARNING OBJECTIVES

• Recognize individual versus aggregate partnership taxation concepts

• Recognize the significance of a partner’s basis in his partnership interest 

• Identify the tax implication of a partner’s contribution of services in exchange for an interest in the partnership

• Recognize specified characteristics of LLCs

• Identify those entities allowed to use the “check the box” regulations

• Identify the way in which single member LLCs are taxed

• Identify LLC members that typically would not be subject to self-employment taxes

• Recognize the methodology for the allocation of liabilities to LLC members

• Recognize the significance of a partner’s basis in his partnership interest

• Identify the differences between recourse and nonrecourse debt and their relationship to partnership basis

• Recognize the individuals typically personally liable for entity debt

• Identify the conceptual methodology for allocating nonrecourse debt

• Identify the conceptual methodology for allocating recourse debt

• Recognize the tax implications of contributions of property to a partnership in exchange for a partnership interest under Section 721

• Identify the criteria of a disguised sale in partnership taxation

• Identify the characteristic of a partnership guaranteed payment 

• Recognize the significance of qualified debt in the context of the disguised sale rules

• Identify the conceptual reasoning behind the Section 751 hot asset rules

• Recognize the tax significance of the hot asset rules on partnership distributions to partners

• Recognize the circumstances under which the hot asset rules will apply 

• Recognize the characteristics of hot assets

• Identify the characteristic necessary for a partnership agreement regarding partner allocations of partnership items to be respected

• Impact of recent developments on partners and partnerships
• The Section 199A qualified business income deduction
• Proper language in partnership agreements for profit and loss allocations
• Analysis of Sections 704 and 752
• Dissecting and reconstructing the partners' capital account
• Partnership distributions and partner's basis for distributed property
• Deficit makeup provisions
• Identification and treatment of "hot assets"
• Disguised sales, including reporting requirements
• Payments to retiring partners or successors of deceased partners
• Anti-abuse regulations