Section 754 and Basis Adjustments for Partnership and LLC Interests
Navigating Complexities in Federal Tax Treatment of Distributions and Sales of Interests
Recording of a 110-minute CPE/CLE webinar with Q&A
This teleconference will provide advisors with a thorough review of both the material terms and practical considerations involved with Sect. 754 elections and basis adjustments for sales or distributions of partnership interests or property.
Outline
- Fundamental issues underlying Sect. 754 and related administrative guidance
- Partnerships choose how basis will be adjusted in event of a distribution or sale
- Sect. 734 distributions of property
- Sect. 743 distributions of partnership interests
- Potential step-up adjustments to basis
- Allocating the step-up
- Potential step-down adjustments to basis
- Sect. 754 election process
- Procedures
- Evaluating future implications of a Sect. 754 election
- Common computation challenges with basis adjustments
- Common reporting issues with basis adjustments
Benefits
The panel will analyze and tackle these and other relevant topics:
- Sect. 754 election rules: How to make a proper election, and the practical pros and cons of doing so.
- Effects of Sect. 754 elections: Effects on depreciation when partnership interests or property is distributed or sold.
- Basis adjustments: Avoiding common mistakes in calculations and reporting.
- Step-ups and step-downs: Understanding the rules for each situation.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty

Janice Eiseman
Principal
Cummings & Lockwood
Her practice specializes in taxation of closely held businesses and tax planning for owners and investors, with a... | Read More
Her practice specializes in taxation of closely held businesses and tax planning for owners and investors, with a particular emphasis on structuring of various business entities. She also has handled tax controversy work before the IRS and New York State tax authorities.
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Craig A. Taylor
Director
Carruthers & Roth
His practice works with closely held businesses, particularly LLCs and especially involving real estate investment and... | Read More
His practice works with closely held businesses, particularly LLCs and especially involving real estate investment and ownership vehicles.
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Craig Gerson
Principal, National Tax Services
PricewaterhouseCoopers
He specializes in partnership taxation issues. Before joining the firm, he worked for four years as an attorney-advisor... | Read More
He specializes in partnership taxation issues. Before joining the firm, he worked for four years as an attorney-advisor with the IRS Office of Chief Counsel (Passthroughs and Special Industries).
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