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Form 15254: Request for Section 754 Revocation

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.

100 minutes
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Certificate of Completion
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Over 35 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

Basics of Section 754 Election

Why Make a Section 754 Election

  • Equalizes Inside and Outside Income Tax Basis
  • Avoids Premature Recognition of Gain From Sale of Partnership Assets

Elements of a Section 754 Election

  • Applies to All Subsequent Periods
  • Results in Increase or Decrease in Inside Tax Basis

Substantial Built-In Loss Rule

  • Prevents Double Benefit of Built-in Losses
  • Mandatory Step Down
  • New Rules for Transfers After 12/31/17

Section 754 and Distributions of Property (Section 734(b)

Termination of Partnerships Pre-2018

  • Ceases Activity
  • Technical Termination
  • Ability to Make New Elections
  • Challenges and Opportunities of Technical Terminations

Terminations After 12/31/17

  • No Longer Technical Terminations
  • No Longer Able to Terminate Elections

Revoking the Section 754 Election After 2017

  • New Form - 15254
  • Examples of Reasons to Revoke Elections
  • Planning for Acceptance
  • Other Considerations
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Why Lorman?

Over 35 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 August 11, 2022.

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

  • AIPB 2.0
     
  • This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     

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

MP3 Download

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

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Why Lorman?

Over 35 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

Robert E. Demmett, CPA, MS

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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Product ID: 409988
Published 2022
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