Advanced Taxation Partnerships & LLCs - Tax Staff Essentials

Description

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 non-liquidating distributions, property basis calculations under various scenarios, and sales of a partnership interest.

Highlights

  • 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

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).
  • 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.

Designed For

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

Leaders

Brian Greenstein

Brian R. Greenstein, Ph.D., is a tenured accounting professor at the Lerner College of Business and Economics at the University of Delaware where he has served for the past 15 years. Previously he held appointments as the Director of Graduate Tax Programs and Chair of the Department of Accounting and Taxation at Seton Hall University as well as Director of Graduate Tax Programs at Drexel University. Dr. Greenstein started his career in the Tax Department of Price Waterhouse (Coopers) and has been affiliated with Fischer Cunnane and Associates (a large local CPA firm in West Chester, PA) for the past 20 years. Brian has presented hundreds of live seminars on various tax and financial planning topics for State CPA societies, private accounting firms, and the Internal Revenue Service. He has also written numerous articles appearing in national publications such as the Journal of Taxation, The Tax Advisor, the CPA Journal, the Journal of Corporate Taxation, Taxes -- The Tax Magazine, The Journal of Real Estate Taxation and Practical Tax Strategies. His research has been quoted by the Supreme Court of the United States in Indopco v. Commissioner, and he actively contributes to the regulatory standard-setting process. Dr. Greenstein specializes in the taxation of flow-through entities, transactional planning, real-estate taxation and planning for high-net worth individuals.