Advanced Taxation LLCs & Partnerships Webcast

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).
• Identify the potential tax consequences when a partner or LLC member makes a contribution of appreciated or depreciated property to the entity.
• Distinguish among the various methods prescribed by the regulations to make required special allocations with respect to contributed property.
• Distinguish between recourse and nonrecourse liabilities of a partnership or LLC.
• 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.
• Recognize which properties will receive a step up or step down in basis when multiple properties are received 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.
• Assess the consequences for the buyer associated with the sale of an interest in a partnership or LLC.

• • Allocation of partnership and LLC income under IRC Section 704(b)
  • Allocations with respect to contributed property
• 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 or LLC assets
  • Sale of an interest in a partnership or LLC
  • "Hot· assets and Section 751 (a)
  • Section 754 elections; Sections 734(b) and 743(b) adjustments
• Section 708 technical termination