Intermediate Partnership Taxation (Half-Day Webinar)

Intermediate Partnership Taxation (Half-Day Webinar)
January 01, 1970
12:00 AM
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The fastest growing tax reporting entity is the LLC taxed as a partnership. Tax practitioners now see partnership tax vehicles used by any type of taxpayer, including large corporations. The flexibility of partnership taxation has much to do with their use, but the distinctions between the “aggregate” and the “entity” approaches create significant uncertainty in many transactions.

This session is “Part II” of a two-part program on partnership taxation. This session will take a deeper dive into some of the more complicated issues in partnership tax reporting and tax planning, including special allocations and how to use them, nonrecourse debt shares, and special problems with distributions.

In this four-hour CPE webinar nationally recognized tax expert and instructor James Hamill, CPA, Ph.D., will explain the best tax-planning strategies for partnership taxation. The session will address two types of allocations – safe harbor and targeted, when Section 704(c) controls allocations, the three-step approach to sharing nonrecourse liabilities, disguised sales, distributions of marketable securities, and distributions that may accelerate recognition of Section 704(c) gains.

Topics Covered

Safe Harbor Allocations
Special allocations of W-2 wages and UBIA for Section 199A
Target allocations
Nonrecourse debt shares
Marketable securities as cash for distribution purposes
Disguised sales
Sections 704(c)(1)(B) distributions
Section 737 distributions
Section 704(b) and tax basis capital account maintenance


Learning Objectives

Describe major concepts relating to contributions to partnerships, basis calculations, transactions between partner and partnership, payments to a retiring partner, distributions of partnership property, and terminations
Recognize the treatment of partnership liabilities
Identify pertinent issues relating to unrealized receivables and substantially appreciated inventory
Describe important rules and concerns relating to special allocations
Discuss important features of the 704(b) and 704(c) regulations
Identify computational and planning issues for the Section 199A deduction
Recognize how to allocate items of profit and loss
Describe how to make special allocations that work
Identify special problems with distributions
Recognize how to maintain Section 704(b) capital and why
Identify and apply the SEE test
Describe safe harbor allocations and how they apply
Recognize three requirements with respect to economic effect
Describe correct statements regarding Section 704(c) allocations
Identify ways in which a risk of loss can arise
Differentiate types of deductions



Number of Hours:
4 (Recommended)

Basic understanding of partnership taxation

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Knowledge Level:

Delivery Method:
Group Internet Based

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Food Included:

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Recommended For:
CPA (4), EA (4), Maryland Registered Preparers (4)

Approved By:
NASBA, IRS, State of Maryland