Reverse 704(c) Allocations: Partnership Revaluations, Triggering Events, and Recent IRS Guidance
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide and drill-down into the complexities of reverse allocations under Section 704(c). The panel will detail the specific circumstances and events under which a partnership may undertake a revaluation through reverse allocation and describe permitted reverse allocations. The panel will also discuss the impact of recent IRS private letter ruling guidance on using partial netting in a reverse allocation revaluation of investment partnerships.
Outline
- Review of partnership allocation rules
- Reverse allocations
- Revaluation methodologies
- Layered reverse allocations
- Regulatory allocations
- Recent IRS Private Letter Ruling on partial netting in revaluation of investment partnership assets
Benefits
The panel will review these and other key issues:
- What are the triggering events that will permit a reverse allocation and revaluing of partnership assets?
- Calculating and maintaining records of “layers” of reverse allocations
- Whether and when revaluations are appropriate or required
- Recent IRS guidance on use of partial netting in revaluation of investment partnership assets
Faculty
![O'Leary, Jennifer A.](/img/t/f002eb8585d5ccfe73fcdf7342afa43f.jpg)
Jennifer A. O'Leary
Partner
Pepper Hamilton
Ms. O'Leary is a partner in her firm's Tax Practice Group. She focuses her practice on the federal income... | Read More
Ms. O'Leary is a partner in her firm's Tax Practice Group. She focuses her practice on the federal income tax aspects of pass-throughs, private investment funds, domestic and international mergers and acquisitions, dispositions, corporate tax restructuring, debt restructuring, regulated investment companies and real estate investments trusts.
Close![Ricketts, Robert](/img/t/8541ac643bbfd41b2b9762fba5961962.jpg)
Robert Ricketts, Ph.D.
Director of School of Accounting
Texas Tech University
Dr. Ricketts has been a member of the Accounting Faculty since 1988 and has held the Frank M. Burke Chair in Taxation... | Read More
Dr. Ricketts has been a member of the Accounting Faculty since 1988 and has held the Frank M. Burke Chair in Taxation since 1999. He is a former Tax Senior with Ernst & Whinney (now Ernst & Young). Dr. Ricketts’ tax scholarship addresses a broad audience, including several courses he co-authors on partnership taxation for the AICPA.
Close![Stauber, David](/img/t/10b85dfdb23190b917b052bef78f95e8.jpg)
David Stauber
Partner
Troutman Pepper
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.
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