Tiered Partnerships: Resolving Tax Law Complexities
Navigating Section 704(b) and (c) Allocations, Disposition of 704 (c) Property and Basis Adjustments
Recording of a 110-minute CLE/CPE webinar with Q&A
Conducted on Thursday, October 17, 2013
Recorded event now available
This CLE webinar will discuss unique allocation issues for tiered partnerships under 704(b) and (c), address application of the allocation rules to mergers and dispositions of 704(c) property, as well as basis adjustments.
Allocation provisions in partnership and LLC agreements are complex to administer and subject to highly specialized rules regarding the handling of gains, losses, depreciation and other tax attributes. These complexities are further magnified when working with tiered partnerships.
Section 704(c) limits the ability of a partner to transfer loss by contributing built-in loss property to a partnership. Practitioners must properly apply the rules relating to the creation and maintenance of multiple layers of forward and reverse section 704(c) gain and loss to tiered partnerships.
There are consequences under Sections 704(c) and 737 of certain partnership mergers and the treatment of section 704(c) layers in connection with partnership mergers. In disposing of 704(c) property, special rules apply to coordination between the upper and lower tier partnerships regarding basis adjustments.
Listen as our authoritative panel of practitioners guides you through special tax issues with tiered partnerships, including 704(b) and (c) allocations, mergers, dispositions of 704(c) property and the attendant basis adjustments issues.
- Section 704(b) allocations in tiered partnerships
- Section 704(c) allocations in tiered partnerships
- Mergers of tiered partnerships
- Disposition of Section 704(c) property
- Special basis adjustments
The panel will review these and other key questions:
- How do the allocation rules apply to the creation and maintenance of multiple layers of forward and reverse section 704(c) gain and loss to tiered partnerships?
- What are the consequences under Sections 704(c) and 737 of certain partnership mergers and the treatment of section 704(c) layers in connection with partnership mergers?
- How has the IRS interpreted basis adjustments and the Section 754 election with respect to tiered partnerships?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Upon completing this seminar you will have obtained an understanding of how to apply allocation rules for tiered partnerships, including 704(b) and (c) allocations, mergers, dispositions of 704(c) property and the attendant basis adjustments issues.
Skadden Arps Slate Meagher & Flom,
Mr. Schockett advises public and private companies on a broad range of U.S. federal income tax issues, with particular focus on mergers, acquisitions, dispositions, joint ventures, debt and equity offerings, bankruptcy restructurings and tax-equity financings. His practice includes significant work in the renewable energy sector.
Amanda Wilson, Partner
Lowndes Drosdick Doster Kantor & Reed,
Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety of complex federal tax matters, with a particular emphasis on pass-through entities such as partnerships, S corporations and real estate investment trusts. Specifically, she focuses on advising clients on the formation, operation, acquisition and restructuring of pass-through entities.
CLE On-Demand - Streaming Audio
Note: Self-study CPE and EA credits are not offered on this On-Demand webinar.
Includes recorded streaming audio of full program plus PDF handouts.
On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.
AK, AZ, CA, CO, CT, DE, FL, GA, HI, IA, ID, IL, IN*, KS, KY, LA, ME, MN, MO, MT, NC, ND, NH**, NJ, NM, NV, NY, OH*, OK, OR, PA, SC, TN, TX, UT, VA, VT, WA, WI, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.
**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.
CLE On-Demand Audio $297.00
Includes full event recording plus handouts.
Note: Self-study CPE and EA credits are not offered on recorded events.
Strafford is an approved provider and self-study CLE credit is available in most states.
AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
Strafford will process CLE credit for one person on each recording.
Additional copies of a recording can be purchased at a discount. Please call Strafford Customer Service toll-free at 1-800-926-7926 ext 10 or email firstname.lastname@example.org to place your order.
Recorded Webinar Download $297.00
Recorded Audio Download (MP3) $297.00
DVD (Slide Presentation with Audio) $297.00 plus $9.45 S&H
NASBA CPE Sponsor
Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
IRS Approved Provider
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Strafford webinars offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program). Please note that our webinars do not feature videos of the presenters.
Many states grant CLE credits for on-demand streaming audio programs and recorded events. Our programs are pre-approved in many states. Refer to our state CLE map for state-specific information.
Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.
Note: Group internet listening requires a proctor.
The entire program was excellent.
Farella, Braun + Martel
Strafford's webinar was easily accessible.
Cranfill Sumner & Hartzog
The seminar featured very knowledgeable presenters on an extremely important topic.
The speakers were knowledgeable and presented useful information.
A very good nuts and bolts program on what to do in this area.
The Law Office of Carol Coplan Babbitt
Tax Law Advisory Board
Steptoe & Johnson
Morrison & Foerster
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Holland & Knight
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Ivins, Phillips & Barker
Managing Director, State and Local Tax Practice
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.