Structuring Targeted Partnership Tax Allocations: Complying With IRC 704(b)
Determining Substantial Economic Effect, Distinguishing Targeted and Regulatory Allocations
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers with the guidance necessary to implement targeted partnership tax allocations correctly. 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 IRC 704(b) requirements, 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?
Robb A. Longman
Longman & Van Grack
Mr. Longman represents his clients in business matters, tax planning and litigation, as well as estate planning. He... | Read More
Mr. Longman represents his clients in business matters, tax planning and litigation, as well as estate planning. He regularly assists businesses with the drafting of corporate documents, drafting contracts, negotiating contracts, addressing employee agreements, and formulating succession planning. Mr. Longman’s clients have continued to grow their businesses into large profitable companies.Close
Winston & Strawn
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.Close