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
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.
Outline
- 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
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
Faculty
Eduardo Chung
Principal
Mazars
Practice Leader for the Tax Practice and Procedures Group, Mr. Chung has over a decade of experience representing... | Read More
Practice Leader for the Tax Practice and Procedures Group, Mr. Chung has over a decade of experience representing individuals, estates, C corporations, Subchapter S corporations and other flow-through entities. He has served on a number of engagements advising on laws applicable to and the policies and procedures followed by the IRS and the various state and local tax jurisdictions in the examination of tax returns, administrative appeals of examination determinations, tax court litigation, and the collection of outstanding tax liabilities.
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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
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide range of clients–including private and public companies, joint ventures, funds, high-net-worth individuals, C-Suite executives, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. Ms. Fuller advises clients on both purely domestic transactions and transnational ones, helping both U.S.-based companies and foreign companies (and their executives) achieve the best possible results from a tax and business perspective. Ms. Fuller is Chair of the ABA’s Tax Section’s Tax Policy Committee, and also Co-Chair of the International Tax Committee of the ABA’s worldwide International Law Section. She frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals.
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Toni Mazzacca
Partner
Mazars
Ms. Mazzacca has over 20 years of experience delivering insightful local, federal and global tax services to clients in... | Read More
Ms. Mazzacca has over 20 years of experience delivering insightful local, federal and global tax services to clients in the financial services, capital markets, banking, insurance, real estate, investment management, and private equity industries. She has a substantial track record of helping clients improve their tax positioning at the local, national and international levels, including achieving compliance with ongoing changes in tax regulations worldwide.
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CPE credit is not available on downloads.
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