Course ID: PTAI

Partnership and LLC Taxation: Advanced Issues

Congress has modified the audit rules for partnerships, adding additional complexity to an already complex area. This program covers allocation of basis in debt, step up in basis upon transfer, disguised sales, abandonment of partnership interest, special allocations of income and deductions, reallocation of depreciation among partners, reporting income from forgiveness of indebtedness, determining an LLC member’s self-employment income, and more. This is the program that gets participants ready to help their clients plan partnership and limited liability company transactions to minimize taxes.


LEARNING OBJECTIVES
  • Recognize tax traps and pitfalls in the organization and operation of partnerships and LLCs
  • Calculate the special allocations required for Section 704(c) property
  • Deal with common ownership changes
  • Handle Section 754 elections and related adjustments
  • Apply rules properly when passing income and other items through to owners
  • Plan and properly account for income from forgiveness of debt
  • Handle the balance sheet after required tax adjustments

MAJOR TOPICS
  • Special tax considerations when organizing a partnership
  • Contributions of property to capital-Secs. 721, 722, and 723
  • Liabilities and their allocation to owners’ basis-Sec. 752
  • Determination of “owners’ distributive share including special allocations-Sec. 704(b)
  • Adjustments for contributed property-Sec. 704(c)
  • Optional adjustments to the basis of entity property-Sec. 754 election
  • Distribution of “HOT” assets-Sec. 751
  • Payments to a retiring partner or member-Sec. 736
  • The revised consolidated audit regime
  • Current developments-court cases and IRS rulings

DESIGNED FOR
CPAs who advise their clients regarding planning for partnership and/or limited liability company transactions and/or who have review responsibility for partnership or limited liability company tax compliance. May also be suitable for public practice.

FIELD OF STUDY
Taxes

PREREQUISITES
None

COURSE PRODUCER
Loscalzo Associates

CPE CREDITS
8.0

LEVEL
Advanced
 

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