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

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Conducted on Thursday, October 17, 2013

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Course Materials

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.

Description

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.

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Outline

  1. Section 704(b) allocations in tiered partnerships
  2. Section 704(c) allocations in tiered partnerships
  3. Mergers of tiered partnerships
  4. Disposition of Section 704(c) property
  5. Special basis adjustments

Benefits

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.

Faculty

Paul Schockett
Paul Schockett
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

Wilson, Amanda
Amanda Wilson
Shareholder
Lowndes

Ms. Wilson concentrates her practice on federal tax planning and structuring and represents clients in a wide variety...  |  Read More

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