Partnership Taxation: Level I Self-Study Webinar

To provide tax professionals with a comprehensive understanding of basic and complex partnership taxation issues. You'll be equipped to identify problems and opportunities in transactions involving partnership formation, transactions with partners, basis, partnership distributions, allocations and other key areas.

DETAILED LEARNING OBJECTIVES

• Recognize the role of IRC Subchapter K 

• Identify the entity associated with double taxation

• Recognize the organizations included in the definition of a partnership

• Identify those entities not allowed to elect partnership taxation under the “check the box” regulations 

• Recognize the time frame for which an unincorporated entity electing to be taxed as a partnership cannot change the election

• Recognize a partnership’s allowable methods of accounting

• Recognize the ownership threshold for which a corporation and a partnership are related for purposes of Section 267

• Identify partnership elections made at the partner level

• Identify the types of partnership income which would flow to the partner as income subject to self-employment tax

• Identify the IRS’ view on a non-managing LLC member for purposes of self-employment taxes

• Recognize the characteristics necessary to a non-managing LLC member in order to avoid self-employment tax from the operations of the entity

• Identify the new ownership threshold at which a partner’s contribution of property in exchange for a partnership interest triggers income recognition

• Identify additional circumstances under which non-recognition treatment of contributed property to a partnership will not apply

• Determine the threshold at which “investment company” rules apply to an exchange of property for a partnership interest

• Determine the threshold at which contributions of appreciated property to a partnership for a partnership interest disguised sale rules will apply

• Determine the tax ramifications of personal services in exchange for a partnership interest

• Determine a partnership’s basis in property contributed by a partner

• Recognize circumstances in which a partner would not be able to deduct his share of partnership loss

• Recognize those circumstances where capital basis computed under the tax basis will generally agree to “inside basis”

• Recognize transactions which would decrease a partner’s basis in his partnership interest

• Determine the allocation of recourse debt

• Identify the effect of recourse debt on a partner’s basis

• Identify the primary characteristic of nonrecourse debt

• Identify the number of allocation tiers when allocating nonrecourse debt

• Identify the default category of nonrecourse debt

• Recognize the treatment of subsidiary debt by the partners of the parent partnership

• Recognize the primary distinction between tax basis and at-risk basis

• Recognize the applicability of the at-risk rules

• Recognize the characteristics of qualified nonrecourse debt

• Calculate a partnership’s basis in remaining partnership property after a property distribution with a built in loss

• Recognize the cash distribution categories under partnership taxation rules

• Recognize the characteristics of a guaranteed payment

• Recognize the implications of a partnership’s distribution of cash to a partner

• Determine when a partnership distribution of partnership property will result in taxable gain to the partner

• Identify the ramifications to the partner who receives a current distribution of partnership property

• Calculate a partner’s basis in property received in a partnership distribution

• Calculate a partner’s basis in his partnership interest after receiving a property distribution

• Identify the treatment of a distribution of “hot assets” to the partner

• Calculate the gain or loss on the sale of a partnership interest

• Recognize the consequences of a partnership’s liquidating payment to a retiring partner

• Recognize the required allocation method when a partnership elects a Section 754 basis adjustment upon the sale/purchase of a partner’s partnership interest

• Recognize the mechanics of making a Section 754 election

• Recognize the circumstances under which a Section 754 election is allowed

• Introduction to, and formation of, partnerships
• The Section 199A qualified business income deduction
• Accounting methods and other operating rules
• Contributions of property and services
  – Minimizing tax recognition
  – Disguised sales
• Basis in the partnership interest
  – Inside vs. outside basis
  – At-risk basis vs. tax basis
  – Effect of partnership liabilities
  – Recourse vs. nonrecourse debt
  – General vs. limited partners
• Partnership distributions
• Stepped-up basis under Section 754
• Partner/partnership transactions
• Terminations, liquidations, transfers of interest and related compliance issues
• Passive activity rules
• Limited liability companies and limited liability partnerships