Applying Waterfall Allocations: Calculating Standard and Complex Layered and Target Allocations
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide flow-through practitioners with the tools necessary to interpret and allocate waterfall provisions in partnership operating agreements. This webinar will review standard allocation methods between partners and members and provide hands-on examples of the corresponding calculations of income and loss, distributions, liquidating distributions, and the maintenance of capital accounts by a partner based on these specifications.
Outline
- Waterfall provisions
- Types of agreements
- Allocation based
- Distribution based
- Types of allocations
- Layered allocations
- Target allocations
- Examples
- IRS requirements
- Issues with waterfall allocations
Benefits
The panel will cover these and other critical issues:
- Differences in layered and target allocations
- How deficit restoration obligations and qualified income offsets affect waterfall allocations
- Maintaining substantial economic effect under IRC Section 704(b)
- The importance of granting override authority in agreements so that allocation provisions function as intended
Faculty
James R. Browne
Partner
Barnes & Thornburg
Mr. Browne advises clients on the U.S. income tax aspects of domestic and international business transactions and... | Read More
Mr. Browne advises clients on the U.S. income tax aspects of domestic and international business transactions and matters involving federal, state and foreign taxes. With more than 35 years of experience, he handles complicated tax and financing issues for a diverse range of clients. He has experience advising sellers and purchasers on tax aspects of business acquisitions involving both strategic and financial purchasers, preparing tax disclosures for debt and equity offering documents, advising clients on tax aspects of forming, funding, and reorganizing corporate and partnership entities, and advising clients on tax and financing aspects of international operations.
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Tanner Yeates
Principal
Holthouse Carlin & Van Trigt
Mr. Yeates has over a decade of experience providing tax consulting, compliance and structuring services and... | Read More
Mr. Yeates has over a decade of experience providing tax consulting, compliance and structuring services and specializes in serving clients structured as pass-through entities, primarily in the private equity and real estate industry sectors. He specializes in providing partnership tax consulting and compliance services. Mr. Yeates' experience includes addressing Hypothetical Liquidation at Book Value accounting, tax modeling, accounting for partnership basis adjustments, waterfall calculations, and other multi-tiered partnership tax issues. He has extensive experience performing financial modeling for complex transactions. Mr. Yeates focuses on the analysis of the tax efficiencies of proposed deal structures and conducts comprehensive tax due diligence.
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