PS: Partnership Formations

General Description:

The Partnership Series is taught on a basic level for new tax professionals. The participant will review the applicable partnership provisions that apply when advising a client to organize a business as an LLC (i.e., transferring property to a partnership).

Learning Objective:

After completing this course the participant will be able to:

• Discuss the tax effect when a person transfers property to a partnership in exchange for an interest in the partnership.
• Recognize when a transfer of property might result in gain, and how to avoid the gain.
• Define "property" for purposes of §721.
• Determine the tax effect of transferring property subject to debt and define debt for §752.
• Describe how the partnership calculates depreciation on property contributed to a partnership and determine when the short-year depreciation rules apply.
• Discuss the disguised sale rules.
• Differentiate between receiving a capital or profits interest in exchange for services and having the interest received subject to a substantial risk of forfeiture.
• Define recourse and nonrecourse debt, and describe the difference between qualified nonrecourse financing and nonrecourse debt.
• Discuss the use of book and tax basis capital accounts.
• Identify the different types of balance sheets for Schedule L of Form 1065.
• Summarize the basic rules that apply when §704(c) property is contributed to a partnership.

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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