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


Tuesday, December 4, 2018

1:00pm-2:30pm EST, 10:00am-11:30am PST

or call 1-800-926-7926

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.

Description

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

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

Tax advisers and counsel must also differentiate between targeted and regulatory allocations. For example, target allocation agreements may not satisfy regulatory safe harbors but can still meet the economic effect equivalence test or the partners’ interest in the partnership test. Failing to come under regulatory safe harbors may 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.

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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 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?

Faculty

Brock, Noel
Noel P. Brock

Assistant Professor
Eastern Michigan University

Mr. Brock is an assistant professor at Eastern Michigan University, where he teaches and researches in the...  |  Read More

Fowler, Lynn
Lynn E. Fowler

Partner
Kilpatrick Townsend & Stockton

Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and...  |  Read More

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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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