Mastering Partnership Minimum Gain Chargeback Provisions for the Tax Professional
Reporting Requirements, Allocations and Planning Opportunities for Non-Recourse Deduction Chargebacks
Recording of a 110-minute CPE webinar with Q&A
This webinar will give tax advisers and professionals a deep and practical guide to understanding the planning opportunities and compliance requirements that arise from “minimum gain chargeback” provisions in partnership agreements. The panel will go into detail on what the chargeback provisions mean, and will provide detailed instruction with examples on the book and tax adjustments and allocations required to account for chargeback provisions.
- Definition of minimum gain and Treas. Reg. 1.704-2(d) provisions
- Chargeback allocations
- Ordering rules
- Exceptions to chargeback rules
- Special circumstances
- Case study involving calculations
The panel will discuss these and other critical questions:
- What should a minimum gain chargeback provision look like?
- How does a minimum gain chargeback provision operate to allocate previously-claimed non-recourse deductions?
- How do minimum gain chargebacks get reported on tax returns?
- What are common mistakes in reporting chargebacks and how can they be avoided?
- How does an adviser recognize planning opportunities in avoiding chargebacks?
Baker & McKenzie
Mr. Haddad concentrates his practice on advising US and non-US clients on federal income tax issues. He provides tax... | Read More
Mr. Haddad concentrates his practice on advising US and non-US clients on federal income tax issues. He provides tax structuring advice to corporations, partnerships, limited liability companies, and other pass-through entities. He is also experienced in tax matters related to joint ventures, private equity fund investments, and real estate transactions, including fund and REIT structures.Close
Paul D. Patrow
Faegre Baker Daniels
Mr. Patrow advises corporations on tax strategies during business formation and transactions. He is experienced in... | Read More
Mr. Patrow advises corporations on tax strategies during business formation and transactions. He is experienced in acquisitions, dispositions, financings, private equity transactions, and domestic and international joint ventures. He also represents private equity and hedge fund sponsors in connection with the formation and operation of investment funds and the acquisition and disposition of investments. Additionally, he advises venture capital investors on the tax implications of their investments in operating companies. He also assists with tax planning for domestic and international real estate investment transactions and with the tax aspects of bankruptcy and private workouts.Close
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