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Partnerships and Section 704(c)

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 recognize the general concepts surrounding a 704c.
  • You will be able to identify the general concepts regarding Forward Allocations.
  • You will be able to identify what events trigger a revaluation.
  • You will be able to differentiate between the three methods of allocation.

91 minutes
Course Exam
Certificate of Completion
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Why Lorman?

Over 34 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 34 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 2.0 including Taxes 2
     
  • 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: www.nasbaregistry.org. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.0 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.0 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 34 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 Tax Group of Reed Smith LLP’s Pittsburgh office
  • Practice includes counseling in all areas of federal income taxes, including corporations, partnerships, specialty entities, such as RICs, REITs and REMICs, and international tax transactions (outbound and inbound)
  • Frequent speaker before a variety of tax, legal, and business groups
  • Adjunct Professor of Law at the University of Pittsburgh School of Law
  • Author and co-author of numerous publications related to business and taxation, including Rethinking the Obvious: Choice of Entity After the Tax Cuts and Jobs Act, Pittsburgh Tax Review, Volume 16 (2018) http://taxreview.law.pitt.edu
  • Member of Pittsburgh Tax Club and Allegheny Tax Society
  • LL.M. degree, New York University School of Law; J.D. degree, cum laude, University of Pittsburgh School of Law; B.A. degree, summa cum laude, University of Pittsburgh
  • Court Admissions include U.S. Tax Court, U.S. District Court - Western District of Pennsylvania, and State Supreme Court - Pennsylvania

• Can be contacted at 412-288-3298 or [email protected]

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Why Lorman?

Over 34 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: 406348
Published 2019
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