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 course 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.
Outline
- Overview of Section 704(b) capital account maintenance rules
- Overview of Section 704(c)
- "Forward" Section 704(c): contributions of built-in gain or built-in loss property
- Revaluations: when are book-ups or book-downs permitted, how are they done, and what are the consequences?
- "Reverse" Section 704(c): tax allocations following a book-up or book-down
Benefits
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 and book-downs
- Recognize the benefits and detriments of revaluations
- Determine when unrecognized Section 704(c) gains and losses must be reported on Schedule K-1
Faculty
Professor Noel P. Brock
Assistant Professor
Eastern Michigan University
Professor Noel P. Brock is an associate professor at Eastern Michigan University where he teaches and researches in all... | Read More
Professor Noel P. Brock is an associate professor at Eastern Michigan University where he teaches and researches in all areas of tax law with specific emphasis on business (partnership, corporate and international) taxation. He teaches primarily in the Master of Tax Program. Prior to entering academia in January 2012, he spent over 18 years in private practice—most recently, he was a partner and the partnership tax practice leader in the Washington National Tax Office of Grant Thornton LLP. Prior to joining Grant Thornton LLP, Professor Brock practiced in with international accounting and law firms where he represented clients in transactional tax matters including partnership, international, corporate and financial products transactions. Since entering academia, Professor Brock has remained engaged in practice on a part time basis and is currently a Principal with Holthouse Carlin & Van Trigt LLP.
Professor Brock’s research focuses on business taxation and accounting education. Among the awards he has received since entering academia include being awarded researcher of the year twice. His research has been published in in leading international and national journals, including The Tax Adviser, Journal of Accountancy, Journal of Passthroughs, Journal of International Taxation, Tax Notes, The Journal of Legal Tax Research, Practicing Law Institute, and CCH TAXES, The Tax Magazine, among others. His work been cited by other leading tax professionals and in major tax treatises.
Professor Brock has spoken at international, national and regional tax conferences, including the ABA Section of Taxation, The 67th Annual University of Chicago Federal Tax Conference, District of Columbia Bar, Strafford Publications, A.L.I. CLE, AICPA, Private Equity International, and the Atlanta Tax Forum.
Professor Brock also remains very active in both the AICPA (as former chair and associate member of the Partnership Technical Resource Panel) and the ABA (former chair of and current member of the Partnerships & LLCs Committee, and Member of the Corporate Taxation Committee).
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Jose Carrasco
Managing Director
Grant Thornton
Mr. Carrasco is a Managing Director in the partnership tax group of Grant Thornton’s Washington National Tax... | Read More
Mr. Carrasco is a Managing Director in the partnership tax group of Grant Thornton’s Washington National Tax Office. He consults on technical issues affecting entities and their owners in transactions involving partnerships, such as mergers, disguised sales, leveraged acquisitions, and other partnership formation and liquidation events. Mr. Carrasco has authored and co-authored articles in publications that include the Tax Adviser and Bloomberg BNA’s Tax Management Memorandum and has presented at tax conferences, including for the American Bar Association Tax Section, District of Columbia Bar, Tax Executives Institute, and AICPA National Tax Conference. He is a Certified Public Accountant in the District of Columbia and North Carolina and is currently the chair of the AICPA’s Partnership Taxation Technical Resource Panel.
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C. Todd Sinnett
Partner, Partnership Taxation
Grant Thornton
Mr. Sinnett is a partner in Grant Thornton’s partnership taxation business. He currently leads the firm’s... | Read More
Mr. Sinnett is a partner in Grant Thornton’s partnership taxation business. He currently leads the firm’s Partnership Capital Account Maintenance services and National Partnership Team. Mr. Sinnett assists clients with tax consulting and tax compliance matters involving partnership annual operations and partnership transactions. Transactional tax matters include, but are not limited to, mergers, disguised sales and contributions involving non-cash property with significant built-in gains and losses, revaluation of partnership capital accounts, transfer of existing partnership interest, redemption of partners, issuance of partnership interest for services, and complete liquidations. Prior to joining Grant Thornton in 2002, Mr. Sinnett worked for Arthur Andersen. His experience includes construction, real estate, hospitality, consumer industrial products, energy, financial services, healthcare and technology.
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