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The course focuses on three major issues that involve allocations by partnerships to partners: (1) assuring that allocations to partners have substantial economic effect under section 704(b); (2) the proper treatment of forward and reverse built-in gains or losses under section 704(c); and (3) the proper characterization of debt and the appropriate allocation of such debt to the partner/LLC members pursuant to section 752.
Attendees will review case studies illustrating the inherent interrelationship of these three subjects and review sample partnership/LLC agreement language.
Note: Course materials include an e-book and PowerPoint slides that reinforce concepts and will be available to attendees.
General knowledge of partnership taxation.
Attorneys and CPAs.
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.