Capital Account Challenges for Partnerships and LLCs: Tackling Calculations and Complex Operating Agreements
Recording of a 110-minute CPE webinar with Q&A
This webinar will give tax professionals preparing Form 1065 tax returns a detailed review of the requirements for capital account maintenance for partnerships and LLCs, including a general review of tax allocations, mathematical examples, explanations of operating agreements, and approaches to compliance.
- General overview of tax allocation principles and substantial economic effect
- Traditional layered approach to allocating income
- Targeted capital account approach to allocating income
- Allocations for hedge funds and commodity funds
- IRS and other taxing authorities views on targeted allocations
The panel will review these and other key issues:
- What are the key tax allocation principles for capital accounts?
- What is the impact of “substantial economic effect” requirements in making capital account allocations?
- How should tax pros handle liquidating distributions and deficit capital account restoration?
- What is the aggregate allocations approach for securities partnerships such as hedge funds and commodity funds?/li>
- What are the various approaches and challenges to special allocations taken by the IRS and other taxing authorities?
Robert A.N. Cudd
Mr. Cudd advises both domestic and foreign entities on tax-efficient structures as well as on transactions between the... | Read More
Mr. Cudd advises both domestic and foreign entities on tax-efficient structures as well as on transactions between the domestic and foreign entities. He has extensive experience in public and private REITs, timber and infrastructure funds, solar and wind projects, energy and pipelines, reorganization of domestic and foreign corporations and partnerships, private equity funds, controlled foreign corporations and PFICs, and bankruptcy and insolvency.Close
Tax – Financial Services
Mr. Ng focuses his practice on tax matters related to hedge funds, private equity investments, and funds-of-funds. He... | Read More
Mr. Ng focuses his practice on tax matters related to hedge funds, private equity investments, and funds-of-funds. He has extensive experience in advising clients on taxation of financial products, derivatives, and other alternative investments. He has written and lectured extensively on both U.S. and offshore hedge fund investments taxation.Close
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CPE On-DemandSee NASBA details.