Special Topics In Partnership And LLC Taxation

Description

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.

Highlights

• 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)

Objectives

• 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.

Designed For

CPAs, attorneys, tax practitioners and financial professionals.