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 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.
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I honestly thought this seminar was fantastic and offered real practical advice.
Jamie (E.) Kinkaid
Johnson Law Office
The program material was well organized and presented in a succinct fashion.
Bass, Berry & Sims
The real case examples and case citations were very helpful.
I appreciated the speakers' practical suggestions on an important topic.
Kilpatrick Townsend & Stockton
Good use of examples from the speakers' practices.
Davis Wright Tremaine
Tax Law Advisory Board
Steptoe & Johnson
Morrison & Foerster
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Transactional Tax Partner
McKenna Long & Aldridge
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Partner, Tax-Exempt Organizations
Steptoe & Johnson
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Ivins, Phillips & Barker
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Sutherland Asbill & Brennan
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