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 754 on transfer of an ownership interest, distributions, selfemployment tax issues, and termination/liquidation of the LLC.
Learning Objectives
- Prepare more complicated partnership returns
- Understand certain advanced concepts of partnership taxation
- Complete the second stage of a graduated professional education program in servicing partnership and LLC clients
Major Topics
- Taking initiative in difficult assignments; can you deliver the QBI message? Full coverage of 199A qualified business income, its calculation, limitations, and examples
- 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 their 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