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Section 754 Elections' Redemption of a Partner 4173339B
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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).

8/18/2017
When: 1:30 PM to 5:00 PM
Where: Webcast
CALCPA
4173339B
United States
Presenter: Gary R. McBride JD, CPA, LLM
Contact: April Deneault
801-466-10322


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Curriculums:   Partnerships and LLCs,Business and Industry,Financial Leadership Forum

NASBA Credit Category:  Taxes

CPE Hours:  4

Description

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.



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

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.
     

Level:  Intermediate

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.

Advanced Prep:

None.

Prerequisite

General knowledge in partnership taxation.

Price:

Members: $120

Nonmembers: $188

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