Advanced Taxation LLCs & Partnerships - Tax Staff Essentials

Addressing the complexities of partnership taxation

Subchapter K, which covers partnership taxation, is extensive and always subtly changing. Course materials cover all the rules and regulations, including explanations of advanced concepts, to help you effectively serve your business and individual partner clients.

Advanced distribution rules for advanced situations

Sometimes, your partnership and LLC clients want to complete transactions that can have complex tax effects. This course explains the taxation of:

• Special allocations
• Liquidating and nonliquidating distributions
• Property basis calculations

Tips for advising clients on the sale of a partnership interest

The sale of an interest in a partnership or LLC can have significant tax implications. Materials cover the intricacies of the process, including:

• Hot assets
• Installment sales
• Sale of passive interests

Partnership and LLC tax planning ideas

Professionals with an in-depth understanding of partnership taxation can apply their knowledge to find ways to provide their clients with valuable advice and tax planning strategies, updated with the most recent legislation and IRS guidance affecting partnerships and LLCs.

Part of Tax Staff Essentials Level 4

This self-study online course is part of Tax Staff Essentials Level 4, a comprehensive learning program that provides tax managers, directors, and partners with the advanced technical training required to work with their most sophisticated clients.

This course can be purchased individually or as part of the Tax Staff Essentials Level 4 bundle.

Who Will Benefit

Managers and partners in public accounting who assist clients with tax planning for closely held LLCs and partnerships

Key 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 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

Learning Outcomes

• Evaluate whether a special allocation in a partnership agreement meets the alternate test for economic effect.
• Assess the interaction between Section 704(b) “book” allocations and Section 704(c) “tax” allocations with respect to contributed property under the traditional method.
• Assess the effect of changes in the partnership’s recourse liabilities on a partner’s basis in the partnership and potential gain recognized due to the change.
• Contrast between recourse and nonrecourse liabilities and the implication of partner guarantees.
• Evaluate the tax implications arising from non-liquidating distributions consisting of either cash or property.
• Assess the factors determining whether a basis adjustment is necessary or desired following the distribution of partnership property to a partner.
• Assess the tax implications for both sellers and buyers when a partnership or LLC interest is sold using the installment method.