Understand the benefits and detriments of a Section 754 Election and why a Partnership may want to revoke the election.
Section 754 elections by partnerships are usually beneficial to its partners in that it equalizes inside and outside basis and prevents premature recognition of gain by new partners. Once the partnership makes the election, it applies to all subsequent years. However, it is possible that the Section 754 election may be counterproductive and result in the elimination of losses or creates an administrative burden to the partners. The removal of the technical termination provisions eliminated an effective way to revoke the elections without the consent of the Internal Revenue Service.
To streamline applications for revocation of Section 754 elections, the IRS has developed procedures and issued a new Form (Form 15254). The Form requires a statement of reasonable cause for revocation of the election. This course will discuss the benefits and detriments of a Section 754 Election and the reasons why a Partnership may want to revoke the election. It will provide instructions for completing Form 15254 and how to plan for acceptance or denial.
Agenda
Faculty
Robert E. Demmett, CPA, MS
WithumSmith+Brown, PC
- Partner in WithumSmith+Brown, PC’s New York office, and has over 30 years of experi-ence
- Certified public accountant in New York
- Specializes in tax and financial planning for high-net-worth individuals, as well as han-dling tax and compliance issues for partnerships, corporations, and other entities; in ad-dition, he helps clients with structure issues, as well as acquisitions and dispositions of businesses and real estate
- Honored by The New York Enterprise Report as one of the recipients of its inaugural “Best Accountants and Attorneys for Growing Businesses Awards,” June 2010
- Lectures for the Foundation of Accounting Education and was an adjunct professor at Queens College Graduate School of the City University of New York
- Can be contacted at [email protected] or 212-829-3210
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