As they gain more experience, staff are expected to take on more complex assignments with minimal supervision. The course is designed to be a step above a mere preparation seminar, including a deeper study into critical areas of formation, special allocations of income and deductions, basis calculations and implications of recourse and nonrecourse debt, basis step-up under §754 on transfer of an ownership interest, distributions, self-employment tax issues, and termination/liquidation of the LLC. Updated for impacts of the Protecting Americans Against Tax Hikes (PATH) Act of 2015.
- Applicable coverage of recent tax acts and any new legislation enacted before presentation
- When do I need to use '704(b) basis' for capital accounts versus ‘tax basis’
- Detailed rules of §704 for preventing the shifting of tax consequences among partners or members
- Unreasonable uses of the traditional and curative allocation methods
- Multiple layers of §704(c) allocations
- Business situations that qualify as are partnerships, and others that do not
- Treatment of recourse versus nonrecourse debt basis
- How to calculate basis limitations and its implication on each partner’s own tax return
- How §179 limitations affect partnership/LLC basis
- Regulations for handling basis step-ups under §754 elections, and mandatory adjustments under §743 and §734 for partnerships who have NOT made the §754 election
- Subsequent contributions of property with §754 adjusted basis to another partnership or corporation
- Capital account adjustments in connection with admission of new member
- Special allocations require ‘substantial economic effect,’ what are the requirements?
- LLCs and self-employment tax to the members
- Distributions -- current or liquidating, cash or property including the substituted basis rule
- Termination/liquidation of an LLC
- Is there a “flexible standard of law” regarding closely held entities?
- Prepare more complicated partnership returns
- Understand certain advanced concepts of partnership taxation
Who should take this course:
Experienced CPAs desiring a comprehensive case approach to understand reasonably complex limited liability company issues and problems; also, CPAs who want a comprehensive, intermediate-level limited liability company practice manual
Experience in business taxation