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.
- 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
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
Jennifer A. O'Leary
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
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
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.Close