Special Topics in Partnership and LLC Taxation
Tax practitioners struggle to understand the rules of Subchapter K of the Internal Revenue Code and related Treasury Regulations. Determine differences between partnership recourse and nonrecourse debt and the consequences of each.
Complex rules offer both tax planning opportunities as well as traps. Join an in-depth analysis of key partnership tax issues, how they affect partnership structuring, and the reporting of partnership results.
- Partnership/LLC formations (IRC Sec. 721)
- Income/loss allocations (IRC Sec. 704(b))
- Allocations related to property with a tax-book difference (IRC Sec. 704(c))
- Partnership/LLC distributions (IRC Secs. 731-732)
- Partner's tax basis and the impact of debt (IRC Sec. 752)
- Inside basis adjustments (IRC Sec. 754)
- Identify fundamental tax planning opportunities and risks related to partnership contributions and distributions.
- Recall the rules for testing partnership allocations under the partner's interest in the partnership test versus the substantial economic effect regulations.
- Determine differences between partnership recourse and nonrecourse debt and the consequences of each.
- Select the best method for making mandatory allocations relating to Section 704(c) property.
- Determine how to apply the optional and mandatory inside basis adjustment rules.
CPAs, attorneys, tax practitioners and financial professionals.
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Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.