Sect. 743(b) Basis Adjustments on Partnership Interests

Resolving Practical Issues Arising From Distributions Under Sections 743(b) and 734(b)

Recording of a 110-minute CPE webinar with Q&A


Conducted on Wednesday, December 14, 2011

Recorded event now available

or call 1-800-926-7926
Program Materials

This teleconference will prepare advisors with an analysis of the election and basis adjustment rules for partnership transfers under Sect. 743(b) and Sect. 734(b) and practical examples to fortify decision-making in this important area of the partnership Code.

Description

Making proper decisions about electing a basis adjustment when a partnership distributes a partnership interest under Sect. 743(b), or to a lesser degree partnership property under Sect. 734(b), can be one of the most challenging issues facing partners and their tax advisors.

How should the step-up or step-down in basis be handled if the partnership assets don't constitute a trade or business? If those assets are used in a trade or business? If the transfer involves so-called "substituted basis exchanges"? The scenarios can be complex, the decisions even more so.

Practical, detailed examples of often-faced partnership transfer issues under Sect. 743(b) and Sect. 734(b), along with some alternative solutions, are invaluable help in advising sound decisions.

Listen as our panel of experienced advisors drills down into practical basis issues with partnership transfers of interest and assets, issues you could well confront in your own work.

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Outline

  1. Sect. 743(b) adjustments on transfer of partnership interests
    1. Transactions giving rise to adjustments under Sect. 743(b)
    2. Mandatory basis adjustments under Sect. 743(b)
    3. Computation of Sect. 743(b) adjustment
      1. Examples showing the complexity
    4. Allocation of Sect. 743(b) adjustment among partnership assets under Sect. 755
      1. Allocation under Sect. 755 upon taxable sales or exchanges
      2. Allocation under Sect. 755 upon non-recognition transactions
  2. Sect. 734(b) adjustments on distributions from partnerships
    1. Transactions giving rise to adjustments under Sect. 734(b)
    2. Mandatory basis adjustments under Sect. 734(b)
    3. Computation of Sect. 734(b) adjustment
      1. Examples showing the complexity
    4. Allocation of Sect. 734(b) adjustment among partnership assets under Sect. 755
  3. Practical situations involving basis adjustments
    1. Analysis of each situation, and alternative solutions
    2. Common computation and reporting issues faced with basis adjustments

Benefits

The panel will tackle these and other relevant topics:

  • Rules governing the ability to make a Sect. 755 election due to a transfer under Sect. 743(b) or Sect. 734(b).
  • How to allocate and calculate a basis adjustment.
  • Practical, detailed examples of partnership transfer scenarios, and analysis of proper decisions in those situations.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Faculty

Barnett, Robert
Robert S. Barnett

Partner
Capell Barnett Matalon & Schoenfeld

Mr. Barnett practice encompasses business and tax planning, estate planning and federal and state tax dispute...  |  Read More

Vishal Amin
Vishal Amin
Senior Manager
KPMG

He is assigned to the firm's Washington National Tax Practice Pass-Throughs Group. Prior to joining KPMG, he worked as...  |  Read More

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