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 course will provide tax advisors, corporate tax professionals and counsel 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 provide you a briefing and analysis on 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.
- Sect. 704(b) considerations for crafting partnership agreements.
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
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
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