IRC Section 754: Partnership and Pass-Through Entity Basis Adjustments

Description

Section 754 is a complex and critical part of the Code for advisers and tax attorneys involved in partnership tax matters. Section 754 sets the framework for an election that allows the partnership to adjust the basis of its assets under certain circumstances. The election provides for a “rebalancing” of partners’ basis in partnership assets and is an integral part of partnership tax practice.

Tax advisers and attorneys must understand not only the rules but also the practical how, why or “why-not” involved in making a Section 754 election. Further, advisers must be prepared to perform the complicated adjustment calculations that the related basis adjustment provisions of Sections 734 and 743 require to track inside basis and depreciation to reach the proper reporting on partners’ individual Schedules K-1.

Listen as our panel of veteran advisers gives you a drill-down on Section 754, sharing their experiences working on complex partnership tax issues to help you understand, identify and avoid missing Section 754 election opportunities. The program will offer concrete examples to illustrate the potential benefits and detriments of a Section 754 election.