Surgent's Partnership and LLC Core Tax Issues From Formation Through Liquidation

Overview

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 steppingstone 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 traªnsfers 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.

Highlights

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
Section 704(b) basis versus tax basis for capital accounts
Detailed rules of §704 for preventing the shifting of tax consequences among partners or members
Unreasonable uses of the traditional and curative allocation methods
Layers of §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 §179 limitations affect partnership/LLC basis
Regulations for handling basis step-ups under §754 elections and mandatory adjustments under §743 and §734 for partnerships that have not made a §754 election
Subsequent contributions of property with §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

Prerequisites

Knowledge and experience in business taxation

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