Professionals need modern solutions to serve the needs of new and existing clients confronted with complex partnership tax issues.
Learning Objectives
- Evaluate whether a special allocation in a partnership agreement meets the alternate test for economic effect.
- Assess the interaction between Section 704(b) “book” allocations and Section 704(c) “tax” allocations with respect to contributed property under the traditional method.
- Assess the effect of changes in the partnership’s recourse liabilities on a partner’s basis in the partnership and potential gain recognized due to the change.
- Contrast between recourse and nonrecourse liabilities and the implication of partner guarantees.
- Evaluate the tax implications arising from non-liquidating distributions consisting of either cash or property.
- Assess the factors determining whether a basis adjustment is necessary or desired following the distribution of partnership property to a partner.
- Assess the tax implications for both sellers and buyers when a partnership or LLC interest is sold using the installment method.
Major Topics
- Allocation of partnership and LLC income under Section 704(b)
- Allocations with respect to contributed property under Section 704(c)(1)(A)
- Allocation of partnership recourse liabilities under Section 752
- Allocation of partnership nonrecourse liabilities and related deductions under Sections 752 and 704(b)
- Advanced distribution rules
- Adjustments to the basis of partnership or LLC assets
- Sale of an interest in a partnership or LLC
- “Hot” assets and Section 751(a)
- Section 754 elections
- Sections 734(b) and 743(b) adjustments
- Section 708 technical termination
