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. Complex rules offer both tax planning opportunities as well as traps. Join an in-depth analysis of key partnership tax issues with an emplasis on 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 inside basis adjustment rules rules.
CPAs, attorneys, tax practitioners and financial professionals.
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.