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

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


Conducted on Wednesday, October 11, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

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.

Description

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.

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Outline

  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.

Benefits

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

Faculty

Raulea, Simona
Simona Raulea
Tax Director
PricewaterhouseCoopers

Ms. Raulea is a Director in the New York Mergers & Acquisitions Group with PricewaterhouseCoopers LLP. Prior to...  |  Read More

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

Ms. Wiesen specializes in partnership taxation, specifically the use of partnerships and limited liability companies in...  |  Read More

Fuller, Pamela
Pamela A. Fuller, JD, LLM (Tax Law)

Counsel
Gremminger Law Firm

Ms. Fuller has broad experience in federal, state, and international tax planning matters. She counsels foreign and...  |  Read More

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