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

An Advanced Case Study of Calculations and Considerations

A live 110-minute CPE webinar with interactive Q&A


Thursday, August 10, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT


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:

  • Ascertain inside basis adjustments
  • Determine the tax consequences of making an IRC 754 election
  • Distinguish IRC 734 and 743 adjustments
  • Identify when downward basis adjustments are required
  • Ascertain when IRC 755 impacts basis adjustments and allocations

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.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $147.00

Live Webinar & CPE Processing $182.00


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ mid-level tax experience preparing complex tax forms and schedules, including supervising other preparers and accountants. Specific knowledge and understanding of partnership taxation, IRC 754 elections, IRC 734(b) basis adjustments and allocation of adjustment under IRC 755; familiarity with the election impact on different partners and utilization of optional basis adjustments.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


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+ mid-level tax experience preparing complex tax forms and schedules, including supervising other preparers and accountants. Specific knowledge and understanding of partnership taxation, IRC 754 elections, IRC 734(b) basis adjustments and allocation of adjustment under IRC 755; familiarity with the election impact on different partners and utilization of optional basis adjustments.

On-Demand Webinar & CPE Processing $182.00


Recorded Event

Includes full event recording plus handouts (available after live webinar).

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

Recorded Webinar Download $147.00
Available 48 hours after the live event

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Recorded Audio Download (MP3) $147.00
Available 24 hours after the live event

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DVD (Slide Presentation with Audio) $147.00 plus $9.45 S&H
Available ten business days after the live event

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Registration Plus Recorded Event

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Live Webinar & Webinar Download $194.00

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Live Webinar & Audio Download $194.00

Recorded Audio Download (MP3) Only $47.00 with Registration/MP3 Combo

Live Webinar & DVD $194.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $47.00 with Registration/DVD Combo


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

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EA Credit

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

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Customer Reviews

The conference was technical, informative and presented at a good pace.

Krystal Ching

KMH

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

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

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Savas Greene & Company

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