[WEB] Selected Partnership & LLC Tax Problems

Description

The program will highlight some of the common partnership problems encountered by LLCs and LLPs.

Objectives

• Discuss the specific tax problems related to LLCs and LLPs, including: classification problems and check-the-box regulations; taxable year-ends; self-employment tax; method of accounting; discharge of indebtedness income; retirement; special allocations.
• Discuss the tax problems associated with contribution of property to a partnership, the application of 704(c) to the contributed property, and reverse 704(c) allocations.
• Identify key terms that are found in an operating agreement.
• Describe the difference between book and tax basis capital accounts and whose obligation it is to keep track of a partner's basis in the partnership.  
• Define the term debt and differentiate between recourse and nonrecourse debt.
• Discuss the tax effect of receiving a capital and/or profits interest for services.
• Determine whether the income generated by an LLC or LLP is subject to self-employment tax.
• Calculate the deduction for qualified business income under 199A and discuss the forthcoming changes to the 199A deduction. 
• Differentiate the tax effects if a member sells its interest to a third party or the LLC redeems a members interest in the LLC.
• Distinguish a current distribution from a liquidating distribution.
• Discuss the pros and cons of advising an LLC to make a 754 election.
• Describe the basic tax effects if a member retires or dies.
• Discuss the 754 election and revoking the 754 election by filing a Form 15254.
• Discuss whether an LLC is a tax shelter which is required to use the accrual method and is subject to the business interest expense rules of Form 8990.
• Discuss the opting out of the partnership audit rules and the business interest expense rules for a partnership engaged in a real property trade or business.
• Discuss using the aggregation rules of 448(c) to determine if average annual gross receipts exceed $26 million.
• Discuss the SALT Parity Act.