Tax Allocation in Partnerships and LLCs
Minimizing Tax Impact Through Strategic Allocation of Income, Gains, Losses and Liabilities
Recording of a 110-minute premium CLE/CPE webinar with Q&A
This teleconference will provide guidance for tax counsel on tax allocation provisions for partnerships and LLCs taxed as partnerships. The panel will outline steps to meet the tax goals for both the partners and the entity.
Outline
-
Allocation of income
- 704(a)
- Constraints of 704(b) and 704(c)
- Economic effect
- Substantiality
- Denied allocations
- Allocation of deductions attributable to non-recourse debt
-
Allocation of contributed property
- Allocations of tax gain or loss
- Cost recovery deductions
- Depreciation methods
- Remedial allocation methods
- Aggregation of properties
- Tiered partnerships
-
Allocation of liabilities
- Recourse liabilities under Section 752
- Non-recourse liabilities and related deductions under Sections 752 and 704(b)
-
Distribution rules
- Distribution of multiple properties
- Cash distributions
- Non-cash distribution
- Receipt of cash and property
-
Adjustments to basis of partnership/LLC assets
- Following transfer of partnership interest
- Distributions of partnership property
- Allocating the adjustment amount among partnership properties
-
Sale of an interest in partnership/LLC
- Tax consequences associated with sale
- Hot assets and Section 751(a)
- Collectibles gain and unrecaptured Section 1250 gain
- Installment sales
- Termination of partnership
Benefits
The panel will review these and other key questions:
- What are the potential economic consequences of a special allocation to a partner or LLC member?
- What are the potential consequences when a partner or LLC member has a negative balance in his/her capital account?
- How do partners bear the economic risk of loss for recourse debt?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Saba Ashraf
Partner
McKenna Long & Aldridge
She concentrates on the structuring and effecting of complex business transactions. Her practice focuses on corporate... | Read More
She concentrates on the structuring and effecting of complex business transactions. Her practice focuses on corporate and partnership taxation with particular emphasis on domestic and international mergers, acquisitions and spin-offs; recapitalizations; leveraged buyouts; going private transactions; partnerships and joint ventures and other subjects.
CloseJed A. Roher
Atty
Godfrey & Kahn
He concentrates his practice on federal corporate and partnership tax law and assists clients with a variety of tax... | Read More
He concentrates his practice on federal corporate and partnership tax law and assists clients with a variety of tax matters ranging from transaction structuring to interactions with the IRS. In addition, he has significant familiarity with state sales tax issues, federal energy tax credits and the Wisconsin Angel Investment tax credit.
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Lynn E. Fowler
Partner
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.
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