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OnDemand Course

Partnership Taxation: Allocations in Partnership and LLC Agreements

Gain a better understanding of calculating the partnership basis adjustments and distributions and the impact on partner level gain or loss calculations.

Every partnership or LLC agreement between at least two members must address tax allocations. Experts have developed provisions that now commonly appear in such agreements to address tax allocations. This topic will provide an overview of those provisions. The material is designed for new tax attorneys who are trying to grasp the complexity of the tax provisions in the typical partnership or LLC agreement and the nontax attorneys and business owners who see those provisions and would like to better understand their purpose. The content will work through examples and sample language to cover the concepts. Although the discussion will inevitably require using technical language and covering technical topics, the discussion is intended to be an overview that covers a broad swath of material.

Learning Objectives

  • You will be able to differentiate between the 704 sections.
  • You will be able to differentiate between the allocation provisions.
  • You will be able to identify the Six Step Targeted Allocations process.
  • You will be able to recognize the steps in the Traditional Five Step approach.

Runtime: 102 minutes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of Partnership Allocations

  • General Tax Rules
  • Substantial Economic Effect
  • Partners' Interests in a Partnership

General Allocation Structures

  • Allocation Driven Structures
    • Basic Proportionate Sharing of Profits and Losses
    • Layer Cake Allocations
  • Distribution Driven Structures
    • Target Allocations
    • Allocations According to Partners' Interests in the Partnership

Basics of Allocation Language in Partnership and LLC Agreements

  • Definitions of Profits and Losses
  • Book Value
  • Special Allocations
    • Minimum Gain Chargeback
    • Qualified Income Offset
  • Regulatory Allocations
    • Section 704(c) Property
    • Allocation of 704(c) Items
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on June 5, 2019.

Call 1-866-352-9540 for further credit information.

  • CPE/NASBA - QAS Self Study 2.5 including Taxes 2.5
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.5 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.5 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board.
     
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Bradley T Borden

Bradley T Borden

Brooklyn Law School

  • Professor of law at Brooklyn Law School
  • Advise, consult, and work as expert witness on matters related to partnership and real estate taxation
  • Have spoken at hundreds of seminars, conferences, and other professional gatherings on matters related to partnership and real estate taxation
  • Written over 100 articles in law reviews and professional journals related to partnership and real estate taxation
  • Wrote multiple books, including Taxation and Business Planning for Partnerships and LLCs (Aspen Publishers, 2017) and LLCs and Partnerships: Law, Finance, and Tax Planning (Wolters Kluwer, 2019)
  • Member, ABA Section of Taxation, NYSBA Tax Section, American Bar Foundation, American College of Tax Counsel
  • J.D. and LL.M. degrees, University of Florida; B.B.A. and M.B.A. degrees, Idaho State University
  • Can be contacted at 718-780-7550 or [email protected]
Anthony L. Minervini

Anthony L. Minervini

Ernst & Young LLP

  • Senior manager in the Partnership Transactional Planning and Economics Group of Ernst & Young’s National Tax Department
  • Practice emphasizes all aspects of partnership taxation
  • Conducts regular seminars and workshops on partnership taxation
  • Member, ABA Section of Taxation, NYSBA Tax Section
  • J.D. degree, University of Pennsylvania Law School; B.A. degree, Loyola University Maryland
  • Can be contacted at [email protected]
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 406356
Published 2019
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