Section 754 Elections on Form 1065: Making Valid Elections, Seeking Relief For Missed or Invalid Elections

Mastering the Mechanics of Election Statements, Schedule K-1, Section 301.9100 Relief and More

A live 110-minute CPE webinar with interactive Q&A

Wednesday, October 11, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, September 22, 2017

This webinar will provide tax advisers and compliance professionals with a thorough, practical guide to the mechanics of reporting a Section 754 election on a partnership's Form 1065 return. The panel will discuss making the election and will detail available relief in instances where a partnership fails to make a timely election.


The Section 754 election is complex and critical for tax advisers serving partnerships. Section 754 allows a partnership to adjust the basis of its assets by election under certain circumstances. The election provides for a “rebalancing” of partners’ basis in partnership assets and is an integral part of partnership tax practice.

Calculation and reporting of 754 adjustments often challenge even experienced practitioners; missed or incorrect elections can result in costly claims against tax practitioners.

Tax compliance professionals must also grasp the mechanics of reporting the elections on Form 1065 and how to obtain relief if an election is incorrect, defective or not timely made.

Making the initial election requires an election statement, identification of partners, and calculations to document basis adjustments reported on Line 13W of each partner’s Schedule K-1. Tax advisers seeking relief under available provisions must provide additional support for any remedy requested.

The Code contains provisions for automatic and discretionary relief in instances of missed or defective elections. There are also procedures to correct basis adjustments and request an invalidation of an election.

Listen as our expert panel provides a practical guide to the tax reporting mechanics of making a Section 754 election, seeking relief for missed elections, and correcting defective elections.


  1. Reporting timely Section 754 election
    1. Calculations
    2. Partners’ consent statements
    3. Documentation required in the absence of partner consent filing
    4. Reporting adjustment amounts on Line 13W of individual partner’s Schedule K-1
  2. Automatic relief for missed or non-timely elections under Section 301.9100-2
  3. Discretionary relief under Section 301.9100-3
  4. Remedies for correcting defective or invalid elections after the filing year
  5. Revocation of a Section 754 election.


The panel will discuss these and other important topics:

  • Documentation that must accompany a Section 754 election on a Form 1065 tax return
  • Who must sign a 754 election?
  • A partnership’s 754 election absent notice from a transferee partner
  • Steps for claiming automatic relief under Section 301.9100-2
  • Seeking Section 301.9100-3 discretionary relief

Learning Objectives

After completing this course, you will be able to:

  • Recognize procedures for making a Section 754 election in the absence of notice from transferee partner
  • Verify where to report the 754 election on partners’ Schedule K-1
  • Identify necessary steps to obtain automatic relief for missed 754 election under Section 301.9100-2
  • Determine how to make a 754 election in the absence of partner information statement


Simona Raulea, Tax Director
PricewaterhouseCoopers, New York

Ms. Raulea is a Director in the New York Mergers & Acquisitions Group with PricewaterhouseCoopers LLP. Prior to joining the New York practice, she spent few years in the Washington National Tax Services Group specializing in partnership taxation. She assists clients with partnership tax consulting services related to strategic joint ventures, cross border and domestic restructuring, private equity transactions and disposition transactions. She is a Certified Public Accountant.

Dina A. Wiesen, Senior Manager, National Tax Office, Passthroughs
Deloitte Tax, New York

Ms. Wiesen specializes in partnership taxation, specifically the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions and restructurings. She joined Deloitte Tax LLP’s National Tax Office from Cadwalader, Wickersham & Taft LLP where she was an associate in the Tax Department, focusing on matters relating to the taxation of financial instruments and derivatives.

Pamela A. Fuller, JD, LLM
Gremminger Law Firm, Washington, D.C.

Ms. Fuller has broad experience in federal, state, and international tax planning matters. She counsels foreign and U.S. based companies, their executives, and high-net-worth individuals, in structuring their transactions and investments for optimal tax and business results. She is experienced in complex tax issues, including transfer pricing disputes. She helps U.S. persons holding foreign accounts and assets to comply with their U.S. tax filing obligations - including those pertaining to FBAR and FATCA. She frequently publishes in the areas of international tax planning, dispute resolution, capital markets, and comparative securities law.

Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $97.00

Includes Early Discount Savings of $50.00 (through 09/22/17)

Live Webinar & CPE Processing $132.00

Includes Live Webinar Early Discount Savings of $50.00 (through 09/22/17)

CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing partnership and partners tax forms. Specific knowledge and understanding of partnership taxation, partner capital accounts, section 734 and 743 basis adjustments, the tax consequences resulting from partnership distributions and the sale of partnership assets; familiarity with the rules governing IRC 754 calculations, section 754 elections and section 755 allocations.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recorded Event

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Live Webinar & Webinar Download $144.00

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Live Webinar & Audio Download $144.00

Includes Special Savings of $150.00 (through 09/22/17)

Live Webinar & DVD $144.00 plus $9.45 S&H

Includes Special Savings of $150.00 (through 09/22/17)


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Early Registration
Discount Deadline
September 22, 2017
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