Alert

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


Thursday, April 23, 2020

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

or call 1-800-926-7926

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 the partnership’s basis in partnership assets under sections 734 or 743 and is an integral part of partnership tax practice.

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

Tax compliance professionals must also grasp the mechanics of reporting an election 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 each partner's Schedule K-1. Tax advisers seeking relief under available provisions must provide additional support for any remedy requested.

The Code and Treasury regulations contains provisions for automatic and discretionary relief in instances of missed or defective elections. There are also procedures to correct basis adjustments and request 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
  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 Section 754 election?
  • A partnership's Section 754 election absent notice from a transferee partner
  • Steps for claiming automatic relief under Section 9100
  • Seeking Section 9100 discretionary relief

This is an encore presentation with live Q&A.

Faculty

Dai, Jellia
Jellia Dai
Manager
Ernst & Young

Ms. Dai advises clients on all types of U.S. partnership tax issues, with a focus on complex partnership transactions....  |  Read More

Fuller, Pamela
Pamela A. Fuller, JD, LLM

Of Counsel
Royse Law Firm

Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity...  |  Read More

Wiesen, Dina
Dina A. Wiesen
Managing Director, National Tax Office, Passthroughs
Deloitte Tax

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

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