Structuring Targeted Partnership Tax Allocations: Complying With IRC 704(b)

Determining Substantial Economic Effect, Distinguishing Targeted and Regulatory Allocations

A live 90-minute CLE/CPE webinar with interactive Q&A


Wednesday, May 3, 2017 (in 9 days)
1:00pm-2:30pm EDT, 10:00am-11:30am PDT


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.

Description

Targeted partnership tax allocations are a popular choice for allocating income and loss among partners. Tax counsel and advisors must provide clients with guidance on whether this method will capture all of the allowable benefits.

The main concern plaguing taxpayers is compliance with IRC § 704(b) and its complicated regulations. Advisors and counsel must grasp the nuances of these complex rules when drafting targeted tax allocation provisions.

Tax advisors and counsel must also differentiate between targeted and regulatory allocations. For example, target allocation agreements may not satisfy regulatory safe harbors but can still satisfy the regulatory economic effect equivalence test or the partners’ interest in the partnership test. Not satisfying the regulatory safe harbors might impact the availability of other favorable rules.

Listen as our experienced panel guides you in approaches to determine when targeted allocation provisions are beneficial, how to comply with IRC § 704(b), including its substantial economic effect standards, and how to choose between targeted and regulatory allocations and drafting best practices.

Outline

  1. Targeted versus regulatory allocations
  2. Benefits and detriments of targeted allocations
  3. IRC § 704(b) requirements
    1. Substantial economic effect
    2. Economic effect equivalence
    3. Partners’ interests in the partnership
  4. Targeted allocation agreement drafting best practices

Benefits

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?

Learning Objectives

After completing this course, you will be able to:

  • Distinguish targeted versus regulatory partnership allocations
  • Determine the benefits of targeted allocations
  • Identify the risks of targeted allocations
  • Recognize IRC Section 704(b) requirements

Faculty

Lynn E. Fowler, Partner
Kilpatrick Townsend & Stockton, Atlanta

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.

Noel P. Brock, Assistant Professor
Eastern Michigan University, Ypsilanti, Mich.

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.


Live Webinar

Live Webinar $297.00

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This webinar is eligible for at least 1.5 general CLE credits.

CLE credits are not available for PR.

*In KS, OH, PA, for more than 1 attendee on the connection you must contact Strafford CLE via email or call 1-800-926-7926 ext. 35 prior to the program for special instructions.


CPE on Live Event

Continuing Professional Education credit processing is available for an additional fee per person. You may register for CPE credit processing at any time before or after the program. To qualify for CPE you may not listen via the telephone.

This program is eligible for 1.5 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business, public or law firm experience at mid-level within the organization, preparing complex tax forms and schedules for partnerships and individual partners; supervisory responsibility over other attorneys/preparers/accountants. Specific knowledge and understanding of IRC 704(b) and partnership structure; familiarity with income and loss allocation among partners, IRC Section 704(b) and the economic effect equivalence test.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

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CLE On-Demand Video $297.00
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Recorded Event

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Recorded Audio Download (MP3) $297.00
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Registration Plus Recorded Event

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Live Webinar & Webinar Download $394.00

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Live Webinar & Audio Download $394.00

Recorded Audio Download (MP3) Only $97.00 with Registration/MP3 Combo

Live Webinar & DVD $394.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $97.00 with Registration/DVD Combo


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Tax Law Advisory Board

Patrick Derdenger

Tax Partner

Steptoe & Johnson

Edward Froelich

Of Counsel

Morrison & Foerster

Daniel L. Gottfried

Partner

Hinckley Allen

J. Leigh Griffith

Partner and Practice Group Leader - Tax

Waller Lansden Dortch & Davis

Mark Lange

Partner

Holland & Knight

Lori Mathison

Partner, Cross-Border Transactions Tax

Fraser Milner Casgrain

Christian McBurney

Federal Tax Partner

Nixon Peabody

Suzanne Ross McDowell

Partner, Tax-Exempt Organizations

Steptoe & Johnson

Todd Reinstein

Partner, Corporate Tax and Due Diligence

Pepper Hamilton

Alex Sadler

Partner

Ivins, Phillips & Barker

Susan Seabrook

Partner

Bingham McCutchen

Peter Stathopoulos

Managing Director, State and Local Tax Practice

Bennett Thrasher

Eric Tresh

Partner & Co-Chair, State & Local Tax Practice

Sutherland Asbill & Brennan

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