IRC 732(d) Partnership and LLC Basis Adjustments for Tax Counsel
Mastering Elective and Mandatory Basis Adjustments on Distributed Property Absent a Partnership 754 Election
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel with comprehensive guidance on navigating the rules governing mandatory Section 732(d) basis adjustments on distributed property by partnerships where there is no Section 754 election in place. The panel will discuss the application challenges surrounding the basis adjustments, and offer practical tips on when to utilize available elections under Section 732(d) to avoid costly and unanticipated tax consequences.
- Section 732 basis rules
- Elective 732(d) basis adjustments
- Mandatory 732(d) adjustments
- Specific illustrations
- Partnership terminations
- Nonliquidating distributions with 732(d) adjustment
- Liquidating distribution with 732(d) adjustments
- Structuring issues
The panel will discuss these and other important topics:
- Under what circumstances do the regulations require partnerships to apply Section 732(d) special basis adjustments?
- What are the mechanics for making an elective application of the Section 732(d) basis adjustment?
- What are the rules for basis shifting from longer-lived to shorter-lived property?
- What are the ordering rules for 732(d) basis allocation among multiple distributed properties?
William C. Lentine
Mr. Lentine is experienced in corporate tax matters, partnership taxation, mergers & acquisitions and estate... | Read More
Mr. Lentine is experienced in corporate tax matters, partnership taxation, mergers & acquisitions and estate planning for executives and high net worth individuals. He has experience in corporate governance issues including choice of entity considerations, shareholder/director meetings, Dodd-Frank Act compliance and other general corporate law matters, as well as with public and private mergers and acquisitions and assisting foreign companies in establishing U.S. operations.Close
Dina A. Wiesen
Senior Manager, National Tax Office, Passthroughs
Ms. Wiesen specializes in partnership taxation, specifically the use of partnerships and limited liability companies in... | Read More
Ms. Wiesen specializes in partnership taxation, specifically the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions and restructurings. She joined Deloitte Tax LLP’s National Tax Office from Cadwalader, Wickersham & Taft LLP where she was an associate in the Tax Department, focusing on matters relating to the taxation of financial instruments and derivatives.Close