On-Demand


11 CPE

Advanced Taxation LLCs & Partnerships (On-Demand) 2022

On-Demand
11 CPE
  • Instructor

    Robert
    Ricketts

  • Instructor

    Larry
    Tunnell

Learning Objectives

  • Calculate what a partner will receive in complete liquidation of their partnership interest under Title 26 U.S. Code of Federal Regulations (CFR) 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.
  • Analyze the sale of a partnership interest and calculate the amount of gain that must be treated as ordinary income under Section 751(a).
  • Evaluate how the installment method will affect how a partner will report gain or loss on the sale of a partnership interest.
  • Assess the consequences for the buyer associated with the sale of an interest in a partnership or LLC.

Major 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

CPE Credits Available

11 CPE
11
Taxes

Things to Know About This Course

Course Level

  • Advanced

Prerequisites

Basic knowledge of business taxation

Intended Audience

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

Provider

AICPA - Durham

This can not be purchased at this time.