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 premium CLE/CPE webinar with Q&A
This CLE course 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.
- 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.
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... | Read More
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.Close
Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety... | Read More
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.Close