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 premium CLE/CPE webinar with Q&A
This CLE/CPE course 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.
Outline
- The mechanics of a Section 754 election
- 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
- Partnership technical terminations
- Benefits
Benefits
The panel will review these and other key issues:
- Mechanics of making a Section 754 election at the 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
William C. Lentine
Partner
Warner Norcross + Judd
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.
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Matthew R. Romano, CPA, MST
Tax Partner
BBD
Mr. Romano maintains significant expertise with the issues and trends related to investment company taxation and has... | Read More
Mr. Romano maintains significant expertise with the issues and trends related to investment company taxation and has extensive experience with the following: policies and procedures with respect to the use of tax equalization, tax issues resulting from ownership changes, mergers and liquidations, application of the use of derivatives in managing capital gains distributions, tax issues arising from investments in Notional Principal Contracts and other types of swaps contracts, determining optimal year-ends, distribution policies, fund elections, and other fund-specific tax matters, documenting and evaluating tax positions, primary and secondary fund tax reporting, compliance with the RIC Modernization Act of 2010 and subsequent technical corrections.
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