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 self-study 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
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• 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 Self-Study.
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.
Detailed Learning Objectives
• Identify factors which may affect the choice of entity
• Identify the tax characteristics generally associated with partnership taxation
• Identify the entities taxed as a partnership by “default” absent a different “Check the Box Regulations” choice
• Recognize individual vs. aggregate partnership taxation concepts
• Recognize the significance of a partner’s basis in his partnership interest
• Recognize the requirements for electing out of Subchapter K
• Recognize the tax treatment of single member LLCs
• Identify a partnership’s options as to a tax year end
• Identify a partnership’s options as to methods of accounting
• Identify the Section 267 limitations on an accrual method taxpayers’ deferral of the deduction for items payable to a related cash basis taxpayer
• Identify items least likely to be reported separately by a partnership
• Identify elections typically made at the partnership and partner level
• Identify the tax treatment of a partnership’s guaranteed payments
• Recognize the factors determining whether or not limited partners or LLC members are subject to self-employment tax
• Recognize the rules for partners’ ability to deduct health insurance payments paid by the partnership
• Recognize the requirements for a partnership to complete the Schedule M-3
• Identify the tax consequences of the exchange of property for a partnership interest under Section 721(a)
• Identify the exceptions to the general nonrecognition provisions of Section 721(a)
• Identify the characteristics of a partnership investment company
• Identify the characteristics of disguised sales
• Recognize the circumstances under which gain will be recognized upon the contribution of encumbered property in exchange for a partnership interest
• Recognize the consequences of a partner’s contribution of services for an interest in a partnership
• Recognize the components of a partner’s basis in his partnership interest
• Recognize the limitations on a partner’s ability to deduct his share of allocated partnership losses
• Recognize those factors that will increase and decrease a partner’s basis in his partnership interest
• Identify which individuals within partnerships are typically personally liable for entity debt
• Identify the conceptual method by which recourse debt is allocated
• Identify the characteristics of nonrecourse debt
• Recognize the seven factors necessary to ensure a partner’s payment obligation will be treated as recourse debt
• Identify and characterize the three tiers of nonrecourse debt
• Identify the tax implications of the contribution of property to a partnership in exchange for a partnership interest
• Identify the criteria for disguised sale treatment
• Recognize the tax implications of a disguised sale
• Recognize the characteristic and tax implications of guaranteed payments
• Recognize partnership “hot assets” and their implications upon distribution to a partner
• Identify the deduction available to qualifying partners under the Section 199A rules
• Identify the basic calculations used to determine the Section 199A deduction
• Recognize the circumstances under which rental real estate may qualify for the Section 199A deduction
• Identify the circumstances under which trades or businesses may be aggregated for purposes of Section 199A
• Identify the significance of a partner’s at risk basis and its implications for partnership allocations of loss
• Identify the components of a partner’s at risk basis
• Identify the components of a partner’s outside basis and its tax implications
• Identify the characteristics of the new partnership audit regime under the Bi-Partisan Act of 2015
• Recognize the elements of a partnership agreement necessary for the IRS to respect the partner allocations of partnership items
• Recognize the characteristics of the Section 704(b) economic effect safe harbor rules
• Recognize the implications of deficit restoration obligations and qualified income offsets
• Recognize the rules for the allocation of nonrecourse debt
• Recognize the contribution of property rules under Section 704(c)
• Recognize the allocation methods available under Section 704(c)
• Identify the partnership anti-abuse regulations authorizing the IRS to re-characterize a partnership transaction
• Identify a partner’s basis in property received from a partnership in a current property distribution
• Identify a partner’s basis in property received from a partnership in a liquidating property distribution
• Identify the tax ramifications to a partnership when distributing partnership property to a partner
• Identify the tax implications of partnership guaranteed payments
• Identify the tax implications of a partnership distribution of cash and/or marketable securities
• Recognize the rules for allocating partnership items when a partner’s interest varies during the partnership’s tax year
• Recognize the tax ramification to a partner when selling or transferring his partnership interest
• Recognize the conceptual purpose of the Section 754 election
• Recognize the mechanics of a Section 754 step up in basis
• Identify what activities are considered to be passive activities in the context of partnership taxation
• Identify the rules for the deductibility of passive activity losses
• Identify those circumstances that allow a taxpayer to deduct suspended passive losses
• Identify the factors used to determine whether or not an activity or a group of activities constitutes an appropriate economic unit
• Identify the tax implications of transactions unique to real estate partnerships
• Recognize the tax advantages of using LLCs in mergers and acquisitions
• Identify how the limitation on net business interest expense under Section 163(j) is applied to partnerships
• Recognize planning opportunities available to the owners of flow through entities under Section 199A
• Recognize taxation rules unique to real estate partnerships
• Identify the method of allocating the purchase price of acquired property under Section 1060
• Identify the capitalization rules of Section 263A
• Identify the capitalization rules of Section 266
• Recognize the tax treatment of common area cost