Sect. 704(c): Contributions to Partnerships and LLCs
Navigating Unsettled Issues, Complex Rules, and Allocation Method Elections
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a thorough and practical guide to navigating the complex requirements of Section 704(c). The panel will go in depth to identify the contributed property subject to Section 704(c) and will discuss available elections to allocate gain and loss.
Outline
- Critical aspects of Section 704(c)
- Sharing of income, gain, loss, or deduction for property contributed must take account of variations between basis and fair market value at contribution
- The Treasury and IRS' broad authority to determine proper application of allocations
- Navigating complex questions about built-in gain or loss property contributed to a partnership
- Book vs. tax basis
- The "Ceiling Rule"
- Traditional, curative, and remedial allocation methods
- Revaluations
- Mixing bowl rules
- Anti-abuse rules
Benefits
The panel will review these and other key issues:
- Reviewing partnership agreements and other operating documents based on Section 704(c) considerations
- Making choices among the allocation method elections
- Whether and when revaluations are appropriate or required
Faculty
Blane Brown
Senior Manager, M&A Tax
KPMG
Mr. Brown has experience in transactional tax planning, including tax due diligence and structuring advice provided in... | Read More
Mr. Brown has experience in transactional tax planning, including tax due diligence and structuring advice provided in connection with mergers, acquisitions and divestitures of business entities as well as experience in tax attribute preservation and utilization planning, stock basis and earnings and profits analysis. His experience spans various segments of the energy industry (both regulated and unregulated) including oil and gas producers, generation, transmission, distribution, and renewables.
CloseBrooke Kotlarsky
Senior Manager, M&A Tax
KPMG
Ms. Kotlarsky is a Senior Manager in KPMG’s Mergers & Acquisitions Tax practice with more than nine years of... | Read More
Ms. Kotlarsky is a Senior Manager in KPMG’s Mergers & Acquisitions Tax practice with more than nine years of experience in structuring and planning for public and privately held clients. She is a member of KPMG’s Partnership Transactions Group, which focuses on tax and structuring consultation related to a variety of complex partnership transactions.
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CPE On-Demand