Partnership and LLC Taxation: Advanced Issues, Including Transfers of Interests and Liquidations
Congress has modified the audit rules for partnerships, adding additional complexity to an already complex area. Get ready to help clients plan partnership and limited liability company transactions to minimize taxes. Updated for the Tax Cuts and Jobs Act.
This program covers allocation of basis in debt, step up in basis upon transfer, disguised sales, abandonment of partnership interest, special allocations of income and deductions, reallocation of depreciation among partners, reporting income from forgiveness of indebtedness, determining an LLC member’s self-employment income, and more.
- Special tax considerations when organizing a partnership
- Contributions of property to capital—Secs. 721, 722, and 723
- Liabilities and their allocation to owners’ basis—Sec. 752
- Determination of owners’ distributive share including special allocations—Sec. 704(b)
- Adjustments for contributed property—Sec. 704(c)
- Optional adjustments to the basis of entity property—Sec. 754 election
- Distribution of “HOT” assets—Sec. 751
- Payments to a retiring partner or member—Sec. 736
- Qualified business income and its interaction with partnerships
- The revised consolidated audit regime
- Current developments—court cases and IRS rulings
- Recognize tax traps in the organization and operation of partnerships and LLCs.
- Calculate the special allocations required for Section 704(c) property.
- Identify common ownership changes.
- Learn to handle Section 754 elections and related adjustments
- Outline and apply rules properly when passing income and other items through owners.
- Determine how to properly plan and account for income from forgiveness of debt.
- Identify how to handle the balance sheet after required tax adjustment.
CPAs, financial professionals and tax professionals.
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.