Overview
As they gain more experience, staff are expected to take on more complex assignments with minimal supervision. The course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation, via deeper life-cycle 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 ยง754 on transfer of an ownership interest, distributions, self-employment tax issues, and termination/liquidation of the LLC. With the right blend of legal and tax ramifications of LLC-specific issues, this course identifies all the major areas that are potential sources of increased complexity.
Major Topics:
- Reporting requirements for Schedules K-2 and K-3
- Capital account reporting requirements
- Schedule K-1 reporting for §743 adjustments
- Schedule K-1 reporting for §704 gains and losses
- Comprehensive case on partnership/partner application of the business interest deduction
- When 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 & curative allocation methods
- Multiple layers of §704(c) allocations
- 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
Learning Objectives:
- Prepare more complicated partnership returns
- Understand certain advanced concepts of partnership taxation