Partnership and LLC Core Tax Issues from Formation Through Liquidation

Learn how to prepare more complicated partnership returns and take a deep dive into formation, special allocations of income and deductions, and more advanced concepts of partnership taxation.
Highlights

• Coverage of recent tax acts and new legislation
• When to use 704(b) basis for capital accounts vs. tax basis
• Detailed rules of Section 704 for preventing the shifting of tax consequences among partners or members
• Unreasonable uses of the traditional and curative allocation methods
• Multiple layers of Section 704(c) allocations
• Business situations and partnerships that qualify vs. others which do not
• Treatment of recourse vs. nonrecourse debt basis
• How to calculate basis limitations and its implication on each partner’s own tax return
• How Section 179 limitations affect partnership/LLC basis
• Regulations for handling basis step-ups under Section 754 elections, and mandatory adjustments under Sections 743 and 734 for partnerships that have not made the Section 754 election
• Subsequent contributions of property with Section 754 adjusted basis to another partnership or corporation
• Capital account adjustments
• Special allocations require substantial economic effect: What are the requirements?
• LLCs and self-employment tax to the members
• Distributions: Current or liquidating, cash or property, including the substituted basis rule
• Termination/liquidation of an LLC
• Is there a flexible standard of law regarding closely held entities?