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

Note: CLE credit is not offered on this program

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

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Conducted on Tuesday, August 16, 2022

Recorded event now available

or call 1-800-926-7926
Course Materials

This course 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 detail available relief when 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 make an election to adjust the basis of its assets 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 contain automatic and discretionary relief provisions in 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.



  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


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


Chung, Eduardo
Eduardo Chung


Practice Leader for the Tax Practice and Procedures Group, Mr. Chung has over a decade of experience representing...  |  Read More

Fuller, Pamela
Pamela A. Fuller, Esq., J.D., LL.M. (Taxation)

Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group

Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide...  |  Read More

Mazzacca, Toni
Toni Mazzacca


Ms. Mazzacca has over 20 years of experience delivering insightful local, federal and global tax services to clients in...  |  Read More

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