Advanced Taxation LLCs & Partnerships
Presenter
Bruce Nelson,
Director of SALT,
EKS&H, LLP
Overview
Subchapter K, which covers partnership taxation, is extensive and always subtly changing. Course materials cover all the rules and regulations, including explanations of advanced concepts, to help you effectively serve your business and individual partner clients. This course can help you to master the advanced concepts of partnership taxation, so you can provide your clients with valuable advice and tax planning strategies. Updated with the most recent legislation and IRS guidance affecting partnerships and LLCs, this course will guide you through the complicated world of advanced partnership and LLC tax law. Some of the many concepts covered in this course include special allocations, liquidating and nonliquidating distributions, property-basis calculations under various scenarios, and sales of a partnership interest.
Learning Objectives:
- Calculate what a partner will receive in complete liquidation of their partnership interest under Section 704(b) regulations.
- Identify the potential economic consequences of special allocations to a partner or LLC member.
- Distinguish between "book" allocations required under Section 704(b) and "tax" allocations required under Section 704(c).
- Calculate the basis of each property received by a partner or member receiving multiple properties in liquidating and nonliquidating distributions from a partnership or LLC.
- Assess when a partnership or LLC should make a Section 754 election to allow it to increase or decrease the basis of its assets.
Major Topics:
- Allocation of partnership and LLC income under Section 704(b)
- Allocations with respect to contributed property under Section 704(c)(1)(A)
- Allocation of partnership recourse liabilities under Section 752
- Allocation of partnership nonrecourse liabilities and related deductions under Sections 752 and 704(b)
- Advanced-distribution rules
- Adjustments to the basis of partnership/LLC assets
- Sale of an interest in a partnership or LLC
