Partnership Taxation: Allocations in Partnership and LLC Agreements

$199.00

SKU: 410040

Description

Understand the rules governing partnership allocations and the commercial import of choices and elections that can be made.
Partnerships and limited liability companies are among the most common business entity types in the United States. They are prized for their flowthrough tax benefits for both large and small businesses. However, the tax rules governing the allocation of partnership income and loss are among the most technical, complex, and commonly misunderstood in the Internal Revenue Code, resulting in unintended tax consequences. This presentation will help tax and business professionals better understand the rules governing partnership allocations and the commercial import of choices and elections that can be made within those rules.

Date: 2023-01-18 Start Time: 1:00 PM ET End Time: 2:40 PM ET

Learning Objectives

* You will be able to define substantial economic effect and partners interests in the partnership.

* You will be able to describe how 704(b) book allocations differ from tax allocations and the practical import of that difference.

* You will be able to explain how partnership allocations impact commercial negotiations of partnership and credit agreements.

* You will be able to review the tax provisions of basic partnership agreements.

Capital Accounting
• Significance of Capital Accounts
• Substantial Economic Effect
• Partners’ Interests in the Partnership

704(c) Considerations
• 704(c) Goals
• 704(c) Methodologies
• Reverse 704(c) Considerations

Partnership Agreement Allocation Approaches
• Safe Harbor Allocations
• Targeted Capital Accounts

Frequently Negotiated Issues
• Calculating Tax Distributions
• 704(c) Methodologies

Questions and Answers

AIPB ,CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Enrolled Agents ,CPE ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Michael P. Spiro-Finn Dixon & Herling LLP