Event Description

As staff members gain more experience, they are expected to take on more complex assignments with minimal supervision. This course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation. The material provides a deep 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 transfers of ownership interest, distributions, self-employment tax issues, and termination and liquidations of an LLC. With a blend of legal and tax ramifications regarding LLC-specific issues, this course identifies all the major areas that are potential sources of increased complexity.

Designed For

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

Objectives

Prepare complicated partnership returns
Understand certain advanced concepts of partnership taxation

Major Subjects

• Reporting requirements for Schedules K-2 and K-3
• Capital account’s reporting requirements
• Schedule K-1 reporting for Section 743 adjustments
• Schedule K-1 reporting for Section 704 gains and losses
• Comprehensive case on partnership/partner application of the business interest deduction
• Section 704(b) basis versus tax basis for capital accounts
• Detailed rules of Section 704 for preventing the shifting of tax consequences among partners or members
• Unreasonable uses of the traditional and curative allocation methods
• Layers of Section 704(c) allocations
• Treatment of recourse versus nonrecourse debt basis
• How to calculate basis limitations and the implications on each partner’s own tax return
• How Section 179 limitations affect partnership/LLC basis
• Regulations for handling basis step-ups under Section 754 elections and mandatory adjustments under Section 743 and Section 734 for partnerships that have not made a Section 754 election
• Subsequent contributions of property with Section 754 adjusted basis to another partnership or corporation
• Capital account adjustments in connection with admission of new members
• Special allocations and substantial economic effect
• LLCs and self-employment tax to members
• Distributions -current or liquidating, cash or property, and the substituted basis rule
• Termination and liquidation of an LLC