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
An encore presentation featuring live Q&A
A 110-minute CPE webinar with interactive Q&A
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.
- Reporting timely Section 754 election
- Automatic relief for missed or non-timely elections under Section 301.9100-2
- Discretionary relief under Section 301.9100-3
- Remedies for correcting defective or invalid elections after the filing year
- 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 Section 754 election?
- A partnership's Section 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
This is an encore presentation with live Q&A.
Ernst & Young
Ms. Dai advises clients on all types of U.S. partnership tax issues, with a focus on complex partnership transactions.... | Read More
Ms. Dai advises clients on all types of U.S. partnership tax issues, with a focus on complex partnership transactions. She has worked with clients throughout the life cycles of their businesses, from formation (e.g., investment structuring, partnership agreement review) to operations (e.g., allocations, capital account maintenance, tax compliance and reporting) to monetization (e.g., sale of business, IPO). Ms. Dai has advised clients through the IPO process, including IPOs and 144A offering since 2016. Other representative recent experiences include partnership taxable Income allocation modeling including Section 704(c) tracking and Section 704(b) allocation; consulting on complicated tax reform issues and tax restructures which contains Section 743(b) calculation and Section 755 allocation; constructing tax receivable agreement models for up-c structures; and consulting on Section 752 debt allocation issues.Close
Pamela A. Fuller, JD, LLM
Tully Rinckey PLLC & Royse Law
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity... | Read More
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity funds, individuals, C-Suite executives, “start-ups,” and government entities--on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. As a seasoned practitioner and tax technician, Ms. Fuller is accustomed to handling nuanced matters involving highly technical questions of law, policy, and procedure at the federal, state, local, and international levels. She provides sophisticated tax planning services across most industry sectors, including software & emerging digital technologies, financial services, real estate development, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, and retail.
Ms. Fuller also has nearly two decades of experience resolving U.S. federal, state, and foreign tax controversies, as well as asserted tax penalties.Close
Dina A. Wiesen
Managing Director, National Tax Office, Passthroughs
Ms. Wiesen specializes in partnership taxation, specifically the use of partnerships and limited liability companies in... | Read More
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.Close
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