Basis Adjustments for Partnerships and LLCs: Tax Law Challenges
Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections
Recording of a 90-minute CLE/CPE webinar with Q&A
This teleconference will analyze the basis adjustment rules associated with sales, transfers and partnership interests or property distributions; review the impact of the Section 754 election for individual partners and the partnership; and discuss structuring transactions to avoid unintended tax consequences.
- Inside and outside basis issues
- Ability to make 754 election due to a transfer
- What happens under 743(b) when a 754 election is made?
- 755 basis adjustments
- Basis adjustments for partnerships and LLCs
- 734(b) adjustments for distributions from partnerships
- Making a 754 election
- Other nuances for consideration
- Partnership technical terminations
- Adjustments to basis of a corporate partner's stock
- Contingent liabilities and allocations of basis adjustments
The panel will review these and other key questions:
- What are the benefits and disadvantages of making the 754 basis election?
- What are the rules governing step-up and step-down basis adjustments?
- What are the rules for allocating basis adjustments?
- What is the impact of the 754 election on individual partners and the partnership?
- What are common pitfalls in basis adjustments, and what can practitioners do to avoid these pitfalls?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Cummings & Lockwood
Her practice specializes in taxation of closely held businesses and tax planning for owners and investors, with a... | Read More
Her practice specializes in taxation of closely held businesses and tax planning for owners and investors, with a particular emphasis on structuring of various business entities. She also has handled tax controversy work before the IRS and New York State tax authorities.Close
Lynn E. Fowler
Kilpatrick Townsend & Stockton
Mr. Fowler's practice specializes in tax-efficient strategies for a variety of business entity formation,... | Read More
Mr. Fowler's practice specializes in tax-efficient strategies for a variety of business entity formation, financing, operations and disposition transactions. He has worked with clients frequently on federal income tax credits, and taxable and tax-free M&A transactions.Close