IRC Section 734 Adjustments: Distributions of Partnership Property
An Advanced Case Study of Calculations and Considerations
Recording of a 110-minute CPE webinar with Q&A
This course will equip tax professionals with the tools to analyze the impact of a Section 754 election (or lack thereof). The panel will offer a detailed case study and illustration of how to calculate Section 734(b) basis adjustment(s) to assets retained by the partnership after distribution to a partner.
Outline
- The mechanics of a Section 754 election
- 163(j), 168(k), and 199A considerations
- Basis adjustments under Section 734(b)
- Negative adjustment
- Positive adjustment
- Allocation of adjustment under IRC 755
- Tax basis capital reporting considerations
- Case study and illustration
- Special rules
- Planning considerations
Benefits
The panel will review these and other principal issues:
- Making a Section 754 election at the partnership level and understanding "inside basis" vs. "outside basis"
- Understanding the basis adjustment under Section 734(b)
- Calculating Section 734(b) adjustment on retained partnership assets
- Allocating Section 734(b) adjustment to a partnership's remaining assets
- Reporting Section 734(b)adjustments
- Planning considerations and consequences of Section 734(b) adjustments
Faculty

Ashley Kettler, CPA
Tax Senior Manager – Real Estate
Withum Smith+Brown
Ms. Kettler has ten years of experience working in Real Estate. She also has experience in REIT due diligence and REIT... | Read More
Ms. Kettler has ten years of experience working in Real Estate. She also has experience in REIT due diligence and REIT testing and compliance, including review of quarterly asset and income tests, lease review, distribution test, closelyheld tests, research of potential REIT issues.
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Dina A. Wiesen
Managing Director, National Tax Office, Passthroughs
Deloitte
Ms. Wiesen specializes in partnership taxation, specifically the use of partnerships and limited liability companies in... | Read More
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.
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CPE credit is not available on downloads.
CPE On-Demand