Understanding Allocations of Partnership/LLC Debt, Income, Gain, Loss and Deductions Webcast | 4203127B CANCELED
Date: July 8, 2020
Event Start time: 8:30 AM End time: 12:00 PM
Facility: Webcast Event
4.00 CPE: Continuing Professional Education Technical
4.00 CTEC-TX: CTEC - Federal Tax Law Hours Technical
4.00 IRS-TX: IRS Federal Tax Update Technical
3.00 MCLE: MCLE Technical
Field of Interest:
A focus on three major issues involving allocations by partnerships to partners: (1) assuring that allocations to partners will be respected under section 704(b); (2) the override provision of section 704(c) relating to the proper treatment of forward and reverse built-in gains and losses; and (3) the characterization of debt as recourse or nonrecourse and the appropriate allocation of such debt to the partner/LLC members pursuant to section 752.
- Understand the importance of the partners' interest in the partnership test for determining whether allocations in a partnership agreement will be respected.
- Determine whether allocations will be respected under the substantial economic effect test
- Recognize the difference between inside basis, outside basis and capital accounts.
- Understand the events which may result in a negative capital account and identify those partners who are allowed such a negative accout.
- Recognize the meaning and operation of of "qualified income offset," "partnership minimum gain," "partnership nonrecourse deductions," "partner nonrecourse deductions" and "minimum gain chargeback."
- Determine the situations where a partnership may elect to restate the book value of its assets to current fair market value and the benefits and detriments of doing so.
- Identify the three regulatory methods for making 704(c) allocations and the operation of the ceiling rule in each.
- Understand how partnership debt affects the outside basis of partners.
- Distinguish between recourse debt, nonrecourse debt and qualified nonrecourse debt.
- Determine a partner's share of partnership debt.
- Understand the consequences of the contribution of property subject to debt and the receipt of a distribution of property subject to debt on a partner's outside basis.
Level of Difficulty:
- Allocating income, gain, deductions and losses under section 704(b).
- Understanding the Target Capital Account Method and comparing it to the Treasury Method.
- Allocations of built-in gain or loss pursuant to section 704(c).
- Properly characterizing debt as recourse, nonrecourse, or qualified nonrecourse financing.
- Allocating debt to the partners pursuant to section 752.
Three years of relevant experience or an understanding partnership and LLC taxation.
Advanced Prep: Event Notes:
CPAs, attorneys, tax practitioners and financial professionals.