Partnership and LLC Taxation: Advanced Issues, Including Transfers of Interests and Liquidations Web

• Recognize tax traps in the organization and operation of partnerships and LLCs.
• Calculate the special allocations required for Section 704(c) property.
• Identify common ownership changes.
• Learn to handle Section 754 elections and related adjustments
• Outline and apply rules properly when passing income and other items through owners.
• Determine how to properly plan and account for income from forgiveness of debt.
• Identify how to handle the balance sheet after required tax adjustment.

• Special tax considerations when organizing a partnership
• Contributions of property to capital—Secs. 721, 722, and 723
• Liabilities and their allocation to owners’ basis—Sec. 752
• Determination of owners’ distributive share including special allocations—Sec. 704(b)
• Adjustments for contributed property—Sec. 704(c)
• Optional adjustments to the basis of entity property—Sec. 754 election
• Distribution of “HOT” assets—Sec. 751
• Payments to a retiring partner or member—Sec. 736
• Qualified business income and its interaction with partnerships
• The revised consolidated audit regime
• Current developments—court cases and IRS rulings