Focus on section 754 elections and the impact on purchases, inheritances, and partnership distributions (sections 743 and 734). Secondly, focus on redemptions of a partner including those involving the retirement of a partner or the death of a partner (sections 731, 732, 742, and 736).
Discuss these topics while using case studies. Competing concerns of the partners are emphasized: e.g., conflicts between a buying partner or beneficiary and the continuing partners; and conflicts between a redeemed partner and the continuing partners. Form 1065 preparer reporting obligations, partner capital account impact, and pertinent sample language in partnership agreements will also be discussed.
Note: Course materials include an e-book and PowerPoint slides that reinforce concepts and will be available to attendees.
- Sections 754 elections and purchases or inheritances (section 743)
- Section 754 elections and distributions (section 734)
- Section 755 allocation rules
- Liquidating distributions to partners (AKA: redemptions)
- Treatment of retired partners or successors of a deceased partner
- Special treatment relating to a retired or deceased service partner
- Recognize how to make a timely section 754 election.
- Determine how to compute and report the section 743 or 734 adjustments.
- Determine how to allocate the basis adjustments among partnership assets per section 755.
- Identify the circumstances in which the 754 election is deemed made.
- Recognize the benefits and downsides of the election on the partners.
- Identify the conflicts between the partners that result from the election.
- Determine strategies for making a late section 754 election beyond merely a PLR request.
- Distinguish a current distribution from a liquidating distribution.
- Recognize the unique tax considerations related to the retirement or death of a partner.
- Recognize the special rules involving the retirement or death of a service partner.
- Identify the unique IRD issues involving the buy-out of a deceased partner’s successor.
- Recognize the importance of partnership agreement language with respect to the above issues.
Attorneys who draft partnership agreements and advise partnerships; CPAs who prepare forms 1065, 568, 565 and Schedule K-1 for partnerships and LLCs; and CPAs who prepare partner income tax returns (forms 1040 or 1120) and advise partnerships and partn
General knowledge in partnership taxation.
Vendor:CalCPA Education Foundation
Member/Nonmember Fees:120 / 188
CPE:Taxes 4 hour(s)
Yellow Book Credit:No
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