Capital Account Challenges for Partnerships: Tackling Calculations, Complex Operating Agreements, Tax-Basis Reporting
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course 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 outline of tax allocations, mathematical examples, explanations of operating agreements, and approaches to compliance. Our panel will discuss the nuances of negative basis capital accounts, reporting partners' share of net unrecognized Sec. 704(c) gain or loss, and handling other common but complicated reporting scenarios.
- A general overview of tax allocation principles and substantial economic effect
- The traditional layered approach to allocating income
- Targeted capital account approach to allocating income
- Allocations for hedge funds and commodity funds
- Tax-basis capital and 704(c) gain-loss reporting requirements
- IRS and other taxing authorities' views on targeted allocations
The panel will review these and other key issues:
- What are the critical 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 best approach for determining and maintaining tax-basis capital accounts for partners?
- What are the various approaches and challenges to special allocations taken by the IRS and other taxing authorities?
Brian T. Lovett, CPA, JD
Mr. Lovett has extensive experience serving the tax needs of both public companies and closely-held businesses,... | Read More
Mr. Lovett has extensive experience serving the tax needs of both public companies and closely-held businesses, including all aspects of tax compliance for partnerships and corporations. He advises clients with regard to the structure and tax consequences of new business ventures, and assists with restructuring existing businesses for increased tax efficiency. Prior to joining his firm, he was with a “Big 4” accounting firm, working closely with large, multinational real estate investment companies.Close
Faye Tannenbaum, CPA
Ms. Tannenbaum has over 28 years of experience providing tax compliance and consulting services to some of the largest... | Read More
Ms. Tannenbaum has over 28 years of experience providing tax compliance and consulting services to some of the largest entities operating within the United States, including private equity companies, banks, broker-dealers and investment management entities.Close
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