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IRC Section 734 Adjustments for Section 754 Elections: Distributing Partnership Property

An Advanced Case Study of Calculations and Considerations

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

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Thursday, April 18, 2024 (in 5 days)

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

or call 1-800-926-7926

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.


Understanding the Section 754 election and its related basis adjustments is critical for tax professionals serving as advisers to clients owning or managing partnerships. The election allows changes to "inside basis," the bases of assets the partnership owns. Even in the absence of the election, there are mandatory adjustments to inside basis.

Section 734(b) adjustments can have a significant impact when a partnership has a 754 election in effect and makes a distribution to a partner or when a partner has a substantial basis reduction in connection with distribution at a time when the partnership does not have a Section 754 election in effect. Recent changes, including the 163(j) interest limitation, the 199A QBI deduction, and 168(k) bonus depreciation, affect these calculations. Section 734(b) adjustments can have different implications for different partners as well, so tax advisers need to fully grasp the tax consequences of Section 734(b) adjustments.

Tax advisers must understand the rules and grasp the practical calculations, allocations, and reporting mechanics of Section 734(b) adjustments. Failure to understand the "moving pieces" of the 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 calculation and allocation of Section 734(b) adjustments, leaving you prepared to advise on the planning and compliance tasks in the complex area of partnership taxation.



  1. The mechanics of a Section 754 election
  2. Basis adjustments under Section 734(b)
  3. Negative adjustment
  4. Positive adjustment
  5. Allocation of adjustment under IRC 755
  6. Special rules - 163(j), 168(k), 199A, and other considerations
  7. Case study and illustration
  8. Planning considerations


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


Dyer, Marcus
Marcus E. Dyer, CPA, JD

Principal, Team Leader of Tax Controversy

Mr. Dyer manages and reviews all aspects of federal and state tax compliance for C-corporation, S corporation and...  |  Read More

Surkin, Dean
Dean L. Surkin, JD, LLM

Professor (Adjunct)
Pace University Graduate School of Business

Mr. Surkin is an attorney engaged in private practice in the New York metropolitan area. He recently retired from the...  |  Read More

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