IRC 754 Elections for Tax Counsel: Mastering Structuring Considerations of Basis Adjustments

Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections

Recording of a 90-minute CLE/CPE webinar with Q&A


Conducted on Wednesday, May 31, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE/CPE webinar will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss 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.

Description

Understanding the Section 754 election and its related basis adjustments is a critical skill for tax counsel serving as advisers to clients owning or managing partnerships. The election allows adjustments on the “inside basis” of assets the partnership owns.

The basis adjustment can have a significant impact when a partnership has an existing 754 election and admits a new partner, has one partner sell a partnership interest, or when the partnership makes a distribution to a partner. The election and adjustments can have different impacts on different partners, so tax advisers need to fully grasp the tax implications of making the election and utilizing the optional basis adjustments.

Tax advisers must not only understand the rules but also the practical calculations, allocations and reporting mechanics of the 754 election. Counsel may be called upon to help make important decisions with basis and depreciation issues, and to help make complicated adjustment calculations.

Listen as our authoritative panel of tax advisers guides counsel through the basis adjustment rules, discusses the impact of the Section 754 election on individual partners and the partnership, and provides best practices for avoiding potential pitfalls of the election.

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Outline

  1. The mechanics of a Section 754 election
  2. Inside and outside basis issues
  3. Ability to make 754 election due to a transfer
  4. What happens under 743(b) when a 754 election is made?
  5. 755 basis adjustments
  6. Partnership technical terminations
  7. Benefits

Benefits

The panel will review these and other key issues:

  • Mechanics of making a Section 754 election at partnership level and understanding “inside basis” vs. “outside basis”
  • Benefits and disadvantages of making the 754 basis election
  • Rules governing step-up and step-down basis adjustments
  • Rules for allocating basis adjustments
  • Impact of the 754 election on individual partners and the partnership
  • Common pitfalls in basis adjustments, and what can practitioners do to avoid these pitfalls?

Faculty

Professor Bradley T. Borden
Professor Bradley T. Borden

Professor of Law
Brooklyn Law School

Professor Borden’s research, scholarship, and teaching focus on taxation of real property transactions and...  |  Read More

Eiseman, Janice
Janice H. Eiseman

Principal
Cummings & Lockwood

Ms. Eiseman focuses her practice on the taxation of closely held businesses and tax planning for owners and investors....  |  Read More

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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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