Event Description

As they gain more experience, staff are expected to take on more complex assignments with minimal supervision. The course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation, via deeper life-cycle study into critical areas of formation, special allocations of income and deductions, basis calculations and implications of recourse and nonrecourse debt, basis step-up under 754 on transfer of an ownership interest, distributions, self-employment tax issues, and termination/liquidation of the LLC. With the right blend of legal and tax ramifications of LLC-specific issues, this course identifies all the major areas that are potential sources of increased complexity.

Designed For

Experienced Accounting and Financial Professionals desiring a comprehensive case approach to understand reasonably complex limited liability company issues and problems; also, Accounting and Financial Professionals who want a comprehensive, intermediate-l

Objectives

Prepare more complicated partnership returns Understand certain advanced concepts of partnership taxation

Major Subjects

New Schedules K-2 and K-3 Capital account reporting requirements Schedule K-1 reporting for Section 743 adjustments Schedule K-1 reporting for Section 704 gains and losses Comprehensive case on partnership/partner application of the business interest deduction When to use 704(b) basis for capital accounts versus tax basis Detailed rules of Section 704 for preventing the shifting of tax consequences among partners or members Unreasonable uses of the traditional curative allocation methods Multiple layers of Section 704(c) allocations Treatment of recourse versus nonrecourse debt basis How to calculate basis limitations and its implication on each partners’ 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 Section 743 and Section 734 for partnerships who have NOT made the Section 754 election Subsequent contributions of property with Section 754 adjusted basis to another partnership or corporation Capital account adjustments in connection with admission of new member 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

Prerequisites

Knowledge and experience in business taxation

Instructions

None