Partnership & LLC Tax Workshop (Advanced)

General Description:

This one-day course exposes the participant to more difficult tax partnership issues that are not routinely encountered in preparing an easier Form 1065.

Learning Objective:

After completing this course the participant will be able to:

• Describe the basic provisions of §704(c) and explain the term "reverse §704(c) allocation."
• Describe the tax effects of a termination and transactions between a partner and a tax partnership.
• Explain the rules that apply to sale of an interest in a partnership, including unrealized receivables, inventory, and the §754 election, and differentiate between inside and outside basis.
• Describe the tax effects of current distributions, including reporting problems on Schedule K and Schedule K-1, the §754 election, distributions of marketable securities or virtual currencies, and the use of Form 7217.
• Describe the tax effects of a liquidating distribution, including reporting problems on Schedule K and Schedule K-1, the §754 election, and the use of Form 7217.
• Apply the 3.8% Medicare tax to gains and losses from a sale or exchange of an interest in a partnership, as well as to current and liquidating distributions.
• Identify disproportionate distributions under §751(b).
• Describe the tax effects of withdrawing from the partnership, including cross-purchase agreements and payments for a retiring partner's interest in stated and unstated partnership goodwill.
• Identify the tax problems associated with death of a partner, including income in respect of a decedent and self-employment tax, as well as the different tax effects of a cross-purchase agreement, having the estate succeed to the deceased partner's interest, or requiring the partnership to redeem the deceased partner's interest.
• Summarize the different types of special allocations under §704(b)(2), reverse §704(c) allocations, and the allocation of recourse and nonrecourse debt of a partnership and LLC, and differentiate between a waterfall provision and a targeted allocation.

Instructors:

Mark A. Vogel is a retired professor and director of the University of Denver Graduate Tax Program, where for 38 years he taught courses in individual, fiduciary, tax accounting, partnership, and corporate taxation. He is the author of Divorce Taxation Guide (John Wiley & Sons) and Individual Taxation (Shepards/McGraw-Hill). He received a J.D. and LL.M. in Taxation from the University of Denver College of Law and an undergraduate accounting degree from the University of Notre Dame. He is also a CPA licensed in Illinois.

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