Partnership Taxation: Allocations in Partnership and LLC Agreements (OnDemand Webinar)

$199.00

SKU: 410040EAU

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: End Time:

Learning Objectives

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) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Michael P. Spiro-Finn Dixon & Herling LLP

Partnership Taxation: Allocations in Partnership and LLC Agreements (OnDemand Webinar)

$219.00

SKU: 401397EAU

Description

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.

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

No Credit Available

Bradley T Borden-Brooklyn Law School, Anthony L. Minervini – Ernst & Young LLP