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 advisers 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 high priority 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 are the factors to consider in choosing between targeted and regulatory allocations?
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
Lynn E. Fowler
Kilpatrick Townsend & Stockton
Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and... | Read More
Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and implement tax-efficient strategies for varied business formation, financing, operations, and disposition transactions. He has significant experience in advising clients to qualify for a variety of federal income tax credits. He has also been the lead tax advisor on numerous taxable and tax-free M&A transactions as well as a variety of other strategic corporate transactions.Close