IRC Section 734 Adjustments: Applying the 754 Election to Distributions of Partnership Property

An Advanced Case Study of Calculations and Considerations

Recording of a 110-minute CPE webinar with Q&A


Conducted on Thursday, August 10, 2017
Recorded event now available


This webinar will equip tax professionals with the tools and understanding to properly analyze the impact of a Section 754 election. The panel will offer a detailed case study and illustration of how to calculate the Section 734(b) basis adjustment(s) to assets retained by the partnership after a distribution to a partner.

Description

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

Section 734(b) basis adjustments can have a significant impact when a partnership has a 754 election in effect and 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, and especially of the Section 734(b) basis adjustments. Failure to understand the “moving pieces” of the optional basis adjustments under Section 734 can result in unnecessary tax issues for the individual partners—some of whom might be your clients.

Listen as our panel of veteran advisers provides practical guidance in the form of a detailed case study on the ins-and-outs of the Section 734(b) adjustments and allocations, leaving you prepared to advise on the planning and compliance tasks of this complex area of partnership taxation.

Outline

  1. The mechanics of a Section 754 election
  2. Basis adjustments under Section 734(b)
  3. Negative basis adjustment
  4. Positive adjustment
  5. Allocation of adjustment under IRC 755
  6. Case study and illustration
  7. Special rules
  8. Planning considerations

Benefits

The panel will review these and other key issues:

  • Making a Section 754 election at partnership level and understanding “inside basis” vs. “outside basis”
  • Understanding optional basis adjustment under Section 734(b)
  • Calculating the Section 734(b) basis adjustment on retained partnership assets
  • Allocating the Section 734(b) optional basis adjustment
  • Reporting Section 734 basis adjustment on a partner’s tax return
  • Planning considerations and consequences of 734 basis adjustment

 

Learning Objectives

Upon completing this webinar, you will be able to:

  • Distinguish between IRC 734 and 743 basis adjustments.

  • Establish whether IRC 755 impacts basis adjustments and allocations.
  • Ascertain the proper procedures for making and revoking an IRC 754 election.
  • Determine the tax consequences of making an IRC 754 election.
  • Identify when a downward basis adjustment is mandatory.

Faculty

David Patch, Managing Director, National Tax Office Partnership Group
BDO USA, McLean, Va.

Mr. Patch works with clients on a broad range of federal income tax matters and is responsible for the development and delivery of firm training on partnership taxation. Before coming to BDO, he worked in the National Tax Practice Pass-Throughs Group at KPMG.

Dina A. Wiesen, Senior Manager, National Tax Office, Passthroughs
Deloitte Tax, New York

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.


EA Credit

Enrolled Agent credit processing is available for an additional fee per person.

EA Processing $5.00


Recordings

CPE On-Demand

Includes video streaming of full program plus handouts (available within a week of the live webinar).

Strafford is a NASBA-approved CPE provider for On-Demand webinars.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: Printing and reviewing Program Outlines and materials.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: QAS Self-Study.
  • Prerequisite: 

    Three years+ business or public firm experience at mid-level within the organization, preparing partnership and partners’ tax forms. Specific knowledge and understanding of partnership taxation, partner capital accounts, basis adjustments and tax consequences resulting from partnership distributions, and IRC 754 elections, familiarity with IRC 755 allocations and tiered partnerships.

On-Demand Webinar & CPE Processing $182.00


Recorded Event

Includes full event recording plus handouts.

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $147.00

How does this work?

Recorded Audio Download (MP3) $147.00

How does this work?


NASBA CPE Sponsor

National Registry of CPE Sponsors

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

or call 1-800-926-7926

CPE Credit

Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.

or call 1-800-926-7926

EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

or call 1-800-926-7926

Customer Reviews

I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.

Matt Bristow

Cover & Rossiter

I appreciated the flow of the information offered and the ease at which I could follow the handouts.

Larry Bruck

WISS & Company

I loved the tools and handouts. Every CPE class should offer these kind of tools.

Jackie Meyer

Sample and Bailey

I purchased the conference a few minutes after it began and the customer service rep was very helpful and got me signed up and logged into the conference very quickly.

Joanna Johnston

Savas Greene & Company

I liked the concentration on specific issues and examples.

Edita Rimalovsky

Komisar Brady & Co.

or call 1-800-926-7926

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.