Partnership Taxation: Level III—Special Allocation Rules

Overview: 

This seminar is for tax professionals who want to explore the most complex partnership rules. In this practical, hands-on workshop, 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

 

Objective: 

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.

Emphasis: 
  • 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
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Prerequisite: 

Partnership Taxation: Level I or equivalent.
Please bring a calculator.

Preparation: 

No advance preparation required.

Level of Knowledge: 

Advanced.

CPE Credit: 
8.00
NASBA Field of Study: 
Taxes