Structuring Targeted Partnership Tax Allocations: Complying With IRC 704(b)
Determining Substantial Economic Effect, Distinguishing Targeted and Regulatory Allocations
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisors with the guidance necessary to correctly implement targeted partnership tax allocations. The panel will explain the complex requirements of IRC § 704(b) and provide best practices for maximizing the tax benefits of targeting partnership allocations.
- Targeted versus regulatory allocations
- Benefits and detriments of targeted allocations
- IRC § 704(b) requirements
- Substantial economic effect
- Economic effect equivalence
- Partners’ interests in the partnership
- Targeted allocation agreement drafting best practices
The panel will review these and other key issues:
- What are the tax benefits of targeted partnership tax allocation methods when allocating income and loss among partners?
- What are the requirements of IRC § 704(b) and how does it apply to targeted partnership tax allocations?
- What are best practices in drafting targeted allocation provisions?
- What factors must be considered in choosing between targeted and regulatory allocations?
Lynn E. Fowler
Kilpatrick Townsend & Stockton
Mr. Fowler's practice specializes in tax-efficient strategies for a variety of business entity formation,... | Read More
Mr. Fowler's practice specializes in tax-efficient strategies for a variety of business entity formation, financing, operations and disposition transactions. He has worked with clients frequently on federal income tax credits, and taxable and tax-free M&A transactions.Close
Noel P. Brock
Eastern Michigan University
Mr. Brock is an assistant professor at Eastern Michigan University, where he teaches and researches in the... | Read More
Mr. Brock is an assistant professor at Eastern Michigan University, where he teaches and researches in the area of tax law with an emphasis on transactional tax including partnership, corporate, financial products and international taxation. He is also Of Counsel for Steptoe & Johnson, where he focuses his practice in the area of transactional tax in support of energy, corporate service, banking, real estate, and financial services. He is a CPA and has published on targeted tax allocations.Close