Advanced Taxation Partnerships & LLCs - Tax Staff Essentials

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The ins and outs of partnership taxation

Gain a good working knowledge of the IRC’s sophisticated partnership tax rules and regulations so you can effectively serve your business and individual partner clients.

Master the advanced concepts of partnership taxation and provide your clients with valuable advice and tax planning strategies. This course is updated with the most recent legislation and IRS guidance affecting partnerships and LLCs.

Learn more about special allocations, liquidating and nonliquidating distributions, property basis calculations under various scenarios, and sales of a partnership interest.

Who Will Benefit

• Managers and partners in public accounting who assist clients with tax planning for closely held LLCs and partnerships

Key Topics

• Allocation of partnership and LLC income under IRC Section 704(b)
• Allocations with respect to contributed property — 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 or LLC assets
• Sale of an interest in a partnership or LLC
• “Hot” assets and Section 751(a)
• Section 754 elections; Sections 734(b) and 743(b) adjustments
• Section 708 technical termination

Learning Outcomes

• Distinguish between “book” allocations required under Section 704(b) and “tax” allocations required under Section 704(c).
• Recognize the three methods described in the Section 704(c) regulations to make special allocations with respect to contributed property.
• Calculate the gain that can result from reallocation of liabilities when a partner joins a partnership.
• Calculate a partner’s or member’s share of recourse liabilities of a partnership or LLC.
• Calculate the basis of each property received by a partner receiving multiple properties in a liquidating versus nonliquidating distribution from a partnership or LLC.
• Determine when a Section 754 election will allow a partnership or LLC to adjust its basis in its assets.
• Recognize how to allocate required basis adjustments among partnership or LLC assets.
• Determine the tax consequences associated with the sale of a partner’s or member’s interest in a partnership or LLC.
• Determine the tax consequences associated with subsequent dispositions of built-in gain or loss assets following a technical termination.