Tiered Partnerships: Resolving Tax Law Complexities

Navigating Section 704(b) and (c) Allocations, Disposition of 704 (c) Property and Basis Adjustments

Recording of a 110-minute CLE webinar with Q&A


Conducted on Thursday, October 17, 2013
Recorded event now available


This CLE webinar will discuss unique allocation issues for tiered partnerships under 704(b) and (c), address application of the allocation rules to mergers and dispositions of 704(c) property, as well as basis adjustments.

Description

Allocation provisions in partnership and LLC agreements are complex to administer and subject to highly specialized rules regarding the handling of gains, losses, depreciation and other tax attributes. These complexities are further magnified when working with tiered partnerships.

Section 704(c) limits the ability of a partner to transfer loss by contributing built-in loss property to a partnership. Practitioners must properly apply the rules relating to the creation and maintenance of multiple layers of forward and reverse section 704(c) gain and loss to tiered partnerships.

There are consequences under Sections 704(c) and 737 of certain partnership mergers and the treatment of section 704(c) layers in connection with partnership mergers. In disposing of 704(c) property, special rules apply to coordination between the upper and lower tier partnerships regarding basis adjustments.

Listen as our authoritative panel of practitioners guides you through special tax issues with tiered partnerships, including 704(b) and (c) allocations, mergers, dispositions of 704(c) property and the attendant basis adjustments issues.

Outline

  1. Section 704(b) allocations in tiered partnerships
  2. Section 704(c) allocations in tiered partnerships
  3. Mergers of tiered partnerships
  4. Disposition of Section 704(c) property
  5. Special basis adjustments

Benefits

The panel will review these and other key questions:

  • How do the allocation rules apply to the creation and maintenance of multiple layers of forward and reverse section 704(c) gain and loss to tiered partnerships?
  • What are the consequences under Sections 704(c) and 737 of certain partnership mergers and the treatment of section 704(c) layers in connection with partnership mergers?
  • How has the IRS interpreted basis adjustments and the Section 754 election with respect to tiered partnerships?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Upon completing this seminar you will have obtained an understanding of how to apply allocation rules for tiered partnerships, including 704(b) and (c) allocations, mergers, dispositions of 704(c) property and the attendant basis adjustments issues.

Faculty

Paul Schockett
Skadden Arps Slate Meagher & Flom, Washington, D.C.

Mr. Schockett advises public and private companies on a broad range of U.S. federal income tax issues, with particular focus on mergers, acquisitions, dispositions, joint ventures, debt and equity offerings, bankruptcy restructurings and tax-equity financings. His practice includes significant work in the renewable energy sector.

Amanda Wilson, Partner
Lowndes Drosdick Doster Kantor & Reed, Orlando, Fla.

Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety of complex federal tax matters, with a particular emphasis on pass-through entities such as partnerships, S corporations and real estate investment trusts. Specifically, she focuses on advising clients on the formation, operation, acquisition and restructuring of pass-through entities.

Ordering

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE, RTRP, and EA credits are not offered on recorded events.

CLE: Pre-approved for self-study credit in: AK, AZ, CA, CT, HI, MO, MT, NY, OH, TX*, VT, WA, WV. Upon request, self-study credit is also available in: CO, FL, GA, ID*, KY, ME, ND, NE, NH, NM, NV, OR, UT, VA, WI, WY. If you are applying for self-study credit in one of these states, contact Strafford CLE at 1-800-926-7926 ext. 35 or CLE@straffordpub.com. (*Indicates that Strafford needs to process the CLE — see below to purchase this option.)

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Available three business days after the live event

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Available 24 hours after the live event

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Available ten business days after the live event

CD (Audio with Slide PDFs) $49.00 plus $9.45 S&H
Available ten business days after the live event


On-Demand CLE - Audio Recording

Includes streaming audio of full program plus handouts (available 24 hours after live program).

Note: Self-study CPE, RTRP, and EA credits are not offered on on-demand webinars.

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*Not available for transitional attorneys in NY.

On-Demand CLE Audio $149.00
Available 24 hours after the live event

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Tax Law Advisory Board

Patrick Derdenger

Tax Partner

Steptoe & Johnson

Edward Froelich

Of Counsel

Morrison & Foerster

Daniel L. Gottfried

Partner

Hinckley Allen

J. Leigh Griffith

Partner and Practice Group Leader - Tax

Waller Lansden Dortch & Davis

Mark Lange

Transactional Tax Partner

McKenna Long & Aldridge

Lori Mathison

Partner, Cross-Border Transactions Tax

Fraser Milner Casgrain

Christian McBurney

Federal Tax Partner

Nixon Peabody

Suzanne Ross McDowell

Partner, Tax-Exempt Organizations

Steptoe & Johnson

Todd Reinstein

Partner, Corporate Tax and Due Diligence

Pepper Hamilton

Alex Sadler

Partner

Ivins, Phillips & Barker

Susan Seabrook

Partner

Bingham McCutchen

Peter Stathopoulos

Managing Director, State and Local Tax Practice

Bennett Thrasher

Eric Tresh

Partner & Co-Chair, State & Local Tax Practice

Sutherland Asbill & Brennan

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