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Live Webinar

90-minute live streaming program
  • February 20
  • 1:00 - 2:30 pm EST

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OnDemand Webinar

Partnerships and Section 704(c)

February 20

Prevent errors and penalties and gain a better understanding of Section 704(c) provisions.

Many tax professionals and investors in partnerships, LLCs and other entities treated as partnerships struggle with the concepts and the operating rules that apply to Section 704(c). These rules potentially apply whenever property is contributed to such an entity or are distributed from such an entity. The regulations under Section 704(c) provide a very flexible but very complicated set of rules for required allocations that apply to contributions property or to distributions property from an entity that is treated as a partnership.

This topic is designed to help the drafters of the basic operating documents for an entity treated as a partnership, including partnership agreements, operating agreements and trust agreements; the tax return preparers for such entities; and those who structure transactions using such entities, understand and work with the Section 704(c) regulations. There are various elections that are available to adopt methods of allocation under Section 704(c), as well as information on reverse allocations. Failing to have a proper understanding of these provisions can potentially result in unanticipated surprising tax consequences for partners, members and beneficiaries of partnership treated entities.

Learning Objectives

  • You will be able to define general concepts of Section 704(c).
  • You will be able to describe forward allocations.
  • You will be able to discuss reverse allocations.
  • You will be able to explain statutory backstopping of Section 704(c).

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Why Lorman?

Over 32 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

Section 704(c) General Concepts
  • Forward Allocations
  • Reverse Allocations and Section 704(b)
Forward Allocations
  • Book Value vs. Tax Basis Issue
  • Methods of Allocation
    • Traditional Method
    • Curative Allocations
    • Remedial Method
Reverse Allocations
  • Section 704(b) Issue Upon Revaluation of Capital Accounts
  • Aggregation Elections
Statutory Backstopping of Section 704(c)
  • Section 704(c)(1)(B)
  • Section 737
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Why Lorman?

Over 32 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 Webinar

This course was last revised on September 10, 2015.

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

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Live Webinar Registration

  • AIPB 1.5
     
  • This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • AL CLE 1.5
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.5 hours credit.
     
  • AR CLE 1.5
     
  • This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • GA CLE 1.5
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.5 CLE hours.
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • MS CLE 1.5
     
  • This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.5 credit hours.
     
  • MT CLE 1.5
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.5 CLE credits.
     
  • NH MCLE 1.5
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 90 Minutes.
     
  • NJ CLE 1.8
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.8 hours of total CLE credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • TN CLE 1.5
     
  • This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.5 hours of credit.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of CLE credit.
     
  • WA CLE 1.5
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.5 hours of Law & Legal Procedure credit.
     
  • WI CLE 1.5
     
  • This program has been approved by the Board of Bar Examiners for 1.5 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.8
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
     
  • Enrolled Agents 1.0
     
  • This program qualifies for 1.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     
  • CPE 1.8 including Taxes 1.8
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a 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: 1.8 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 1.8 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure 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. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, Inc. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Taxation for 1.5 hours.
     

Who should attend?

This live webinar is designed for accountants, CPAs, CEOs, presidents, vice presidents, CFOs, controllers, business owners and managers, bookkeepers, tax preparers, enrolled agents and attorneys.

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More Program Information

Why Lorman?

Over 32 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

Leo N. Hitt

Leo N. Hitt

Reed Smith LLP

  • Partner in the Pittsburgh office of Reed Smith LLP
  • Member of its tax practice and former head of the Tax, Benefits and Wealth Planning Group
  • Practice emphasizes all aspects of federal income taxation, with particular emphasis in the taxation of business entities, such as partnerships and corporations, securitized and other investment vehicles, including RICs, REITs and REMICs
  • Conducts seminars and workshops on numerous topics for a large number of professional groups, including lawyers, accountants and business people
  • Wrote several publications related to the areas of the federal income taxation of business entities and other related topics
  • Adjunct professor at the University of Pittsburgh School of Law
  • Listed in Best Lawyers in America for tax law for more than 10 years and achieved the highest rating by Martindale-Hubbell Law Directory
  • Board of the Pittsburgh Tax Club and member of the Allegheny Tax Society
  • J.D. degree, University of Pittsburgh School of Law; LL.M. degree, New York University School of Law; B.A. degree, University of Pittsburgh
  • Can be contacted at [email protected] or 412-288-3298
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Why Lorman?

Over 32 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: 404969
Published 2015, 2019
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