Advanced Taxation LLCs & Partnerships - Tax Staff Essentials

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Addressing the complexities of partnership taxation

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.

Advanced distribution rules for advanced situations

Sometimes, your partnership and LLC clients want to complete transactions that can have complex tax effects. This course explains the taxation of:

• Special allocations
• Liquidating and nonliquidating distributions
• Property basis calculations

Tips for advising clients on the sale of a partnership interest

The sale of an interest in a partnership or LLC can have significant tax implications. Materials cover the intricacies of the process, including:

• Hot assets
• Installment sales
• Sale of passive interests

Partnership and LLC tax planning ideas

Professionals with an in-depth understanding of partnership taxation can apply their knowledge to find ways to provide their clients with valuable advice and tax planning strategies, updated with the most recent legislation and IRS guidance affecting partnerships and LLCs.

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

• 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).
• Identify the potential tax consequences when a partner or LLC member makes a contribution of appreciated or depreciated property to the entity.
• Distinguish among the various methods prescribed by the regulations to make required special allocations with respect to contributed property.
• Distinguish between recourse and nonrecourse liabilities of a partnership or LLC.
• 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.
• Recognize which properties will receive a step up or step down in basis when multiple properties are received 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.
• Assess the consequences for the buyer associated with the sale of an interest in a partnership or LLC.