Intermediate Partnership Taxation (Half-Day Webinar)

EVENT DESCRIPTION

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