Mastering Partnership Minimum Gain Chargeback Provisions for the Tax Professional
Reporting Requirements, Allocations and Planning Opportunities for Non-Recourse Deduction Chargebacks
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will give tax advisers and professionals an in-depth and practical guide to understanding the planning opportunities and compliance requirements that arise from "minimum gain chargeback" provisions in partnership agreements. The panelist will go into detail on the impact of chargeback provisions and 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
- A case study involving calculations
The panelist will discuss these and other critical questions:
- How should a minimum gain chargeback provision look?
- 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?
Professor Bradley T. (Brad) Borden
Professor of Law
Brooklyn Law School
Professor Borden’s research, scholarship, and teaching focus on taxation of real property transactions and... | Read More
Professor Borden’s research, scholarship, and teaching focus on taxation of real property transactions and flow-through entities (including tax partnerships, REITs, and REMICs). He teaches Federal Income Taxation, Partnership Taxation, Taxation of Real Estate Transactions, and Unincorporated Business Organizations, and he is affiliated with the Dennis J. Block Center for the Study of International Business Law. His work on flow-through and transactional tax theory appears in articles published in law reviews including Baylor Law Review, University of Cincinnati Law Review, Florida Law Review, Georgia Law Review, Houston Law Review, Iowa Law Review, Tax Lawyer, and Virginia Tax Review, among others. His articles also frequently appear in leading national tax journals including Journal of Taxation, Journal of Taxation of Investments, Real Estate Taxation, and Tax Notes.Close