IRC Sect. 704(b): Partnership Allocations
Navigating Complex Rules to Determine Valid Allocation of Income, Gain, Loss, Deductions or Credits
Recording of a 110-minute CPE webinar with Q&A
This teleconference will provide tax advisors and corporate tax professionals with a review of the key tax concepts for making valid allocations to partners by partnerships and certain LLCs under Sect. 704(b) of the Internal Revenue Code.
Review of partnership allocation rules
- Sect. 704(a) and Sect. 704(b)
- Sect. 704(c) and Sect. 704(d)
- Economic effects tests
Rules for allocations related to non-recourse debt
- Sect. 1.704-2
- Examples of non-resource and partner non-recourse debt
- Partnership minimum gain
Targeted capital accounts vs. liquidating with capital accounts
- Layer cake and targeted allocations
The panel will analyze and tackle these and other relevant topics:
- Terms of the three provisions under Sect. 704(b) to validate an allocation.
- Material details of the leading allocation provision, the two part substantial economic effect test.
- Additional rules to allocate deductions, losses and gains attributable to non-recourse debt.
- Relevant administrative guidance and court rulings.
- Issues arising from Sect. 704(b) that must be anticipated in crafting partnership agreements.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety... | Read More
Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety of complex federal tax matters, with a particular emphasis on pass-through entities such as partnerships, S corporations and real estate investment trusts. Specifically, she focuses on advising clients on the formation, operation, acquisition and restructuring of pass-through entities.Close
Tax Group Practice Leader
Fenwick & West
Mr. Forst's individual practice specializes in international corporate and partnership taxation. He is a lecturer... | Read More
Mr. Forst's individual practice specializes in international corporate and partnership taxation. He is a lecturer on international taxation at Stanford Law School and a frequent writer on related topics.Close