Section 704(c) Capital Account Book-Ups: Revaluation of Partnership Assets
Triggering Events for Revaluations, Effects of Revaluations on Allocations of Tax Items
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers with a practical guide to the complexities of capital account revaluations or "book-ups" under Section 704. The panel will detail the circumstances and events under which a partnership may revalue its property to FMV to adjust the capital accounts of its members.
- Overview of Section 704(b) capital account maintenance rules
- "Forward" Section 704(c): contributions of built-in gain or built-in loss property
- Book-ups: when are they permitted, how are they done, and what are the consequences?
- "Reverse" Section 704(c): tax allocations following a book-up
The panel will review these and other key issues:
Understand the IRC 704(b) capital account maintenance rules.
- Ascertain the impact of contributions of built-in gain or built-in loss property.
- Identify the mechanics of book-ups.
- Recognize the benefits and detriments of revaluations.
- Determine when reporting of unrecognized IRC 704(c) gains and losses must be reported on Schedule K-1.
Nancy L. Langdon
Managing Director, WNTS M&A Tax
Ms. Langdon has 16 years of experience working with clients on a broad range of tax issues and specializes in complex... | Read More
Ms. Langdon has 16 years of experience working with clients on a broad range of tax issues and specializes in complex partnership income tax matters including post acquisition integrations, contributions, distributions, allocations, formations, terminations, conversions, and debt restructuring. Prior to joining the M&A group, she provided tax consulting and compliance services in PwC's Phoenix office, primarily focusing on federal and state income taxes for public and private C-Corporations (including ASC 740 and FIN 48), S-Corporations, partnerships, not-for-profit entities, and high wealth individuals.Close
Senior Manager, WNTS M&A Tax
Ms. Stoner specializes in partnership taxation. She has significant experience assisting clients with complex... | Read More
Ms. Stoner specializes in partnership taxation. She has significant experience assisting clients with complex partnership transactions, from partnership formations to operational issues and unwind transactions. Ms. Stoner’s background includes advising on the federal tax implications of partnership debt restructuring transactions, property contributions and distributions, Section 704(b) revaluations in capital accounts, partner allocations of taxable income including Section 704(c) allocations, application of the disguised sale rules, liability allocations, basis adjustments and the treatment of contractual alliances. She is a former attorney-advisor at the IRS Office of Chief Counsel, Passthroughs & Special Industries division where she drafted the Section 108(e)(8) partnership debt for equity regulations and other published guidance affecting partnerships, S corporations and trusts.Close
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