Partnership Taxation: Level II Webinar

To give CPAs, tax accountants and finance professionals the special knowledge and skills to deal with advanced partnership tax topics and special problems ranging from allocations to complex transactions between the partner and partnership. Participants will analyze the regulations by working through actual examples and reviewing partnership agreements.

• Impact of recent developments on partners and partnerships
• The Section 199A qualified business income deduction
• Proper language in partnership agreements for profit and loss allocations
• Analysis of Sections 704 and 752
• Dissecting and reconstructing the partners' capital account
• Partnership distributions and partner's basis for distributed property
• Deficit makeup provisions
• Identification and treatment of "hot assets"
• Disguised sales, including reporting requirements
• Payments to retiring partners or successors of deceased partners
• Anti-abuse regulations
• At-Risk Rules under Section 465
• Partnership and LLC issues and K-1s

Marjorie Belliotti, Tax Manager, Maillie LLP

Marjorie Belliotti, CGMA, CPA, has over 35 years of experience in both public and private accounting, tax and business process improvement. She currently serves as a Tax Manager for Maillie LLP. A published author, she has developed and taught a variety of tax courses. Ms. Belliotti has expertise in a broad spectrum of US direct and indirect tax areas. Her previous experience includes Manager Income Tax Accounting and Compliance at Sunoco, Inc. and senior level positions at Air Products and Chemicals, Fujirebio Diagnostics, Inc. (FDI) and KPMG. She is proficient in spreadsheet development and has an extensive background in federal and multistate tax compliance and planning. As a public accountant, Ms. Belliotti served a diverse mix of clients in the retail, manufacturing, personal service and construction industries.

To give CPAs, tax accountants and finance professionals the special knowledge and skills to deal with advanced partnership tax topics and special problems ranging from allocations to complex transactions between the partner and partnership. Participants will analyze the regulations by working through actual examples and reviewing partnership agreements.

DETAILED LEARNING OBJECTIVES

• Identify the form used to calculate the §465 at-risk limitation

• Determine the tax consequence when a partner’s amount at risk falls below zero

• Identify when a passive activity loss arises under §469

• Apply the proper ordering of the basis, at-risk, passive activity, and excess business loss limitations

• Determine the treatment of an excess business loss carried to a subsequent tax year

• Calculate the initial outside basis of a partnership interest acquired by purchase

• Determine the initial basis of an inherited partnership interest

• Determine the tax consequences of receiving a vested capital interest in exchange for services

• Identify partnership items that increase a partner’s outside basis

• Determine how nondeductible partnership expenditures affect a partner’s outside basis

• Identify the required method for reporting partners’ capital accounts on Schedule K-1

• Calculate tax-basis capital using the modified outside basis method

• Explain how the sale of a partnership interest can create a difference between inside and outside basis

• Distinguish a partner’s tax-basis capital account from the partner’s outside basis

• Identify the disclosure requirement associated with a bottom-dollar payment obligation

• Determine how a partner’s nonrecourse loan to a partnership is allocated under the economic risk-of-loss rules

• Calculate partnership minimum gain for purposes of allocating nonrecourse liabilities

• Identify the liabilities subject to the three-tier nonrecourse liability allocation framework

• Determine the extent to which debt guaranteed by a disregarded entity is treated as recourse to its owner

• Determine when a current cash distribution produces gain under §731

• Identify circumstances supporting disguised-sale treatment when a contribution and distribution are not simultaneous

• Recognize factors indicating that a contribution and related payment constitute a disguised sale

• Calculate gain recognized in a partial disguised sale using the proportional basis method

• Identify the safe-harbor rate for a reasonable guaranteed payment for the use of capital

• Determine when a preferred return is presumed not to constitute disguised-sale consideration

• Calculate the maximum qualifying distribution under the operating cash flow exception

• Identify items that reduce net cash flow under the operating cash flow exception

• Calculate disguised-sale consideration arising from the assumption of a nonqualified liability

• Identify liabilities that qualify for favorable treatment under the disguised-sale rules

• Determine the disclosure requirement for a contribution and related distribution occurring within two years

• Identify items treated as unrealized receivables under §751

• Determine the ordinary and capital character of gain from the sale of a partnership interest containing hot assets

• Identify a disproportionate distribution under §751(b)

• Apply the hypothetical-sale approach to a disproportionate partnership distribution

• Identify the Schedule K-1 reporting code used to disclose a partner’s share of §751 hot assets

• Identify the information required in a partnership’s §751(b) disclosure statement

• Identify the REIT and publicly traded partnership amounts potentially eligible for the §199A deduction

• Identify where a partnership reports §199A information on Schedule K-1

• Determine when ordinary income recognized under §751 may qualify as QBI

• Identify items excluded from qualified business income

• Determine how guaranteed payments for services affect the recipient’s and partnership’s QBI

• Determine the effect of the taxable-income limitation on an SSTB owner’s §199A deduction

• Identify the requirements for the post-2025 minimum §199A deduction

• Calculate the applicable percentage within the §199A phase-in range

• Calculate the §199A deduction for a non-SSTB owner subject to the W-2 wage and UBIA limitations

• Identify the common-ownership requirement for aggregating businesses under §199A

• Apply the consistency requirement to businesses aggregated for §199A purposes

• Determine how a partnership reports §199A information for multiple trades or businesses

• Identify partnership debt arrangements that increase a partner’s amount at risk

• Identify the requirements for qualified nonrecourse financing under the §465 real-estate exception

• Determine how an increase in a partner’s share of partnership liabilities affects outside basis

• Identify who is responsible for maintaining and substantiating a partner’s outside tax basis

• Explain how an imputed underpayment is assessed under the BBA centralized partnership audit regime

• Apply the partner-counting rules when a partnership with an S corporation partner elects out of the BBA regime

• Explain the authority of the partnership representative under the BBA centralized partnership audit rules

• Impact of recent developments on partners and partnerships
• The Section 199A qualified business income deduction
• Proper language in partnership agreements for profit and loss allocations
• Analysis of Sections 704 and 752
• Dissecting and reconstructing the partners' capital account
• Partnership distributions and partner's basis for distributed property
• Deficit makeup provisions
• Identification and treatment of "hot assets"
• Disguised sales, including reporting requirements
• Payments to retiring partners or successors of deceased partners
• Anti-abuse regulations
• At-Risk Rules under Section 465
• Partnership and LLC issues and K-1s

Marjorie Belliotti, Tax Manager, Maillie LLP

Marjorie Belliotti, CGMA, CPA, has over 35 years of experience in both public and private accounting, tax and business process improvement. She currently serves as a Tax Manager for Maillie LLP. A published author, she has developed and taught a variety of tax courses. Ms. Belliotti has expertise in a broad spectrum of US direct and indirect tax areas. Her previous experience includes Manager Income Tax Accounting and Compliance at Sunoco, Inc. and senior level positions at Air Products and Chemicals, Fujirebio Diagnostics, Inc. (FDI) and KPMG. She is proficient in spreadsheet development and has an extensive background in federal and multistate tax compliance and planning. As a public accountant, Ms. Belliotti served a diverse mix of clients in the retail, manufacturing, personal service and construction industries.