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|CPE Course Details
Partnerships & LLCS: Special Allocations
Wednesday, September 19, 2012
8:30 a.m. - 4:30 p.m. (8:00 a.m. Registration)
Hawaii Society of CPAs
This course will provide guidance and a thorough understanding of the planning opportunities and pitfalls of special allocations, as well as LLC allocations and the sharing of partnership debt.
- Allocations of income and loss with respect to contributed property under the §704(c) regulations, using the traditional method, the traditional method with curative allocations, and the remedial allocation method
- Reverse §704(c) allocations
- Allocations of income and loss under the primary economic effect test
- Allocations under the alternate economic effect test
- Nonrecourse deductions, qualified income offset, and minimum gain chargeback
- Allocations of income and loss under the partner' interest test
- Testing for substantiality
- Allocation of recourse, nonrecourse, and qualified nonrecourse debt
- Treatment of guarantees, assumptions, and indemnification agreements
- Allocation of nonrecourse deductions and liabilities, including minimum gain and gain chargebacks
- Varying interest rule under §706(d)
- Understanding what is necessary in order to create a deficit in the book or tax capital account of a member of an LLC
- At-risk rules as applied to LLCs, including deficit restoration obligations
- Review of an LLC operating agreement.
|CPE Credit Hour/Area
||8 CPE credit hours recommended
||University of Denver Graduate Tax Program
||Mark A. Vogel, CPA
Register by Wednesday, September 5, 2012 and save.