Advanced Taxation LLCs & Partnerships - Tax Staff Essentials

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Rules and regulations

Learn the IRC’s partnership tax rules and regulations to effectively serve your business and individual partner clients.

Partnership taxation concepts

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.

Tax consequences

Learn more about the tax consequences of 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

• 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.