Tax Allocation in Pass-Through Entities
Minimizing Tax Impact Through Strategic Allocation of Income, Gains, Losses and Liabilities
Recording of a 110-minute CPE webinar with Q&A
This teleconference will provide guidance for tax advisers and tax preparers 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.
Allocation of income
- Constraints of 704(b) and 704(c)
- Economic effect
- 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
Sale or redemption of an interest in partnership/LLC
- Allocation of profit/loss in year of sale or redemption
- Allocations relating to potential section 734 basis step up
- Allocations relating to potential section 743 basis step up
- Termination of partnership
The panel will explore these and other important topics:
- 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.
Mr. Hitt's work covers taxation of businesses and business transactions, including syndications of limited... | Read More
Mr. Hitt's work covers taxation of businesses and business transactions, including syndications of limited partnerships and other partnership matters. Among his previous speaking experience is a program on Sect. 704(c) and partnerships.Close
Lynn E. Fowler
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.Close
Peter J. Withoff
Faegre Baker Daniels
Mr. Withoff is a partner in the Tax Group, focusing primarily on federal income tax matters. He has dealt with a wide... | Read More
Mr. Withoff is a partner in the Tax Group, focusing primarily on federal income tax matters. He has dealt with a wide variety of federal income tax issues including taxable and tax-free mergers and acquisitions, complex equity and debt offerings, as well as refinancings and workouts.Close