• Allocation of partnership and LLC income under Section 704(b)
• Allocations with respect to contributed property under Section 704(c)(1)(A)
• Allocation of partnership recourse liabilities under Section 752
• Allocation of partnership nonrecourse liabilities and related deductions under Sections 752 and 704(b)
• Advanced distribution rules
• Adjustments to the basis of partnership/LLC assets
• Sale of an interest in a partnership or LLC
Learning Objectives
When you complete this course, you will be able to: • Calculate what a partner will receive in complete liquidation of their partnership interest under Section 704(b) regulations.
• Identify the potential economic consequences of special allocations to a partner or LLC member.
• Distinguish between “book” allocations required under Section 704(b) and “tax” allocations required under Section 704(c).
• Calculate the basis of each property received by a partner or member receiving multiple properties in liquidating and nonliquidating distributions from a partnership or LLC.
• Assess when a partnership or LLC should make a Section 754 election to allow it to increase or decrease the basis of its assets.
Major Topics
• Allocation of partnership and LLC income under Section 704(b)
• Allocations with respect to contributed property under Section 704(c)(1)(A)
• Allocation of partnership recourse liabilities under Section 752
• Allocation of partnership nonrecourse liabilities and related deductions under Sections 752 and 704(b)
• Advanced distribution rules
• Adjustments to the basis of partnership/LLC assets
• Sale of an interest in a partnership or LLC
