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Overview

8.0 Credits

As they gain more experience, staff are expected to take on more complex assignments with minimal supervision. The course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation, via deeper life-cycle study into critical areas of formation, special allocations of income and deductions, basis calculations and implications of recourse and nonrecourse debt, basis step-up under §754 on transfer of an ownership interest, distributions, self-employment tax issues, and termination/liquidation of the LLC.

Objectives

  • Prepare more complicated partnership returns
  • Understand certain advanced concepts of partnership taxation

Major Topics

  • Applicable coverage of recent tax acts and any new legislation enacted before presentation
  • When to use “704(b) basis” for capital accounts versus “tax basis”
  • Detailed rules of §704 for preventing the shifting of tax consequences among partners or members
  • Unreasonable uses of the traditional & curative allocation methods
  • Multiple layers of §704(c) allocations
  • Business situations & partnerships that qualify; others that do not
  • Treatment of recourse versus nonrecourse debt basis
  • How to calculate basis limitations and its implication on each partner’s own tax return
  • How §179 limitations affect partnership/LLC basis
  • Regulations for handling basis step-ups under §754 elections, and mandatory adjustments under §743 and §734 for partnerships who have NOT made the §754 election
  • Subsequent contributions of property with §754 adjusted basis to another partnership or corporation
  • Capital account adjustments in connection with admission of new member
  • Special allocations require “substantial economic effect”; what are the requirements?
  • LLCs and self-employment tax to the members
  • Distributions -- current or liquidating, cash or property including the substituted basis rule
  • Termination/liquidation of an LLC

Designed For

Experienced CPAs desiring a comprehensive case approach to understand reasonably complex limited liability company issues and problems; also, CPAs who want a comprehensive, intermediate-level limited liability company practice manual

Prerequisite

Experience in business taxation
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