Section 754 Elections—Redemption of a Partner Webcast | 4173339D

Date :
November 13, 2017 12:30 PM - 4:00 PM
Location :
Webcast
Facility :
Webcast Rebroadcast
Level of Difficulty :
Intermediate
Member Price :
140
Nonmember Price :
188
CPE Credits :
CPE 4.00, MCLE 3.00, IRS-TX 4.00, MCLE LS-TX 3.00, CTEC-TX 4.00
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Focus on section 754 elections and the impact on purchases, inheritances, and partnership distributions (sections 743 and 734). Secondly, focus on redemptions of a partner including those involving the retirement of a partner or the death of a partner (sections 731, 732, 742, and 736).

Discuss these topics while using case studies. Competing concerns of the partners are emphasized: e.g., conflicts between a buying partner or beneficiary and the continuing partners; and conflicts between a redeemed partner and the continuing partners. Form 1065 preparer reporting obligations, partner capital account impact, and pertinent sample language in partnership agreements will also be discussed.

Note: Course materials include an e-book and PowerPoint slides that reinforce concepts and will be available to attendees.

Materials are provided as an ebook for this course.

Objectives:

  • Recognize how to make a timely section 754 election.
  • Determine how to compute and report the section 743 or 734 adjustments.
  • Determine how to allocate the basis adjustments among partnership assets per section 755.
  • Identify the circumstances in which the 754 election is deemed made.
  • Recognize the benefits and downsides of the election on the partners.
  • Identify the conflicts between the partners that result from the election.
  • Determine strategies for making a late section 754 election beyond merely a PLR request.
  • Distinguish a current distribution from a liquidating distribution.
  • Recognize the unique tax considerations related to the retirement or death of a partner.
  • Recognize the special rules involving the retirement or death of a service partner.
  • Identify the unique IRD issues involving the buy-out of a deceased partner’s successor.
  • Recognize the importance of partnership agreement language with respect to the above issues.
     

Major Subjects:

  • Sections 754 elections and purchases or inheritances (section 743)
  • Section 754 elections and distributions (section 734)
  • Section 755 allocation rules
  • Liquidating distributions to partners (AKA: redemptions)
  • Treatment of retired partners or successors of a deceased partner
  • Special treatment relating to a retired or deceased service partner

Advanced Prep:

None.

Misc. Information:

This course will adjourn at 4 p.m.

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Level of Difficulty:
Intermediate
Field of Interest:
Taxes
Prerequisites:

General knowledge in partnership taxation.

Designed For:

Attorneys who draft partnership agreements and advise partnerships; CPAs who prepare forms 1065, 568, 565 and Schedule K-1 for partnerships and LLCs; and CPAs who prepare partner income tax returns (forms 1040 or 1120) and advise partnerships and partners on tax-smart strategies.

Instructors

Gary R. McBride, CPA, Esq.

Gary McBride is a principal in Summit Accountancy Group, Inc.; a professor emeritus at California State University, East Bay; and former director of the Graduate Tax Program. He is a licensed attorney and certified public accountant. He worked for the Internal Revenue Service as a revenue agent, special agent, and technical advisor at the IRS National Office. He is author and presenter of four CPE courses for the CalCPA Education Foundation: Federal and California Tax Update for Individuals (with professor Annette Nellen); Federal and California Tax Update for Businesses and Estates (with professor Annette Nellen); Partnerships and LLCs Part I: Formation, Operation, and Allocations; and Federal Taxation of Partnerships and LLCs Part II: Sales, Distributions, Redemptions, and Liquidations. McBride earned his master of laws in taxation degree in 1987 from Georgetown University; his juris doctor degree in 1981 from Hastings College of Law, and his bachelor’s degree (emphasizing accounting and finance) in 1975 from the University of California, Berkeley.

No Agenda or Materials posted.