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.
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.
Outline
- 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
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.
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.
Faculty
Paul Schockett
Skadden Arps Slate Meagher & Flom,
Washington, D.C.
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,
Orlando, Fla.
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.
Recordings
CLE On-Demand - Streaming Audio
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*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.
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CLE On-Demand Audio $297.00
Recorded Event
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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.)
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Tax Law Advisory Board
Tax Partner
Steptoe & Johnson
Of Counsel
Morrison & Foerster
Partner
Hinckley Allen
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Partner
BakerHostetler
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Partner
Arent Fox
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Pepper Hamilton
Partner
Morgan Lewis
Shareholder
Buchanan Ingersoll & Rooney
Peter Stathopoulos
Managing Director, State and Local Tax Practice
Bennett Thrasher
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
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