Partnership Taxation Concepts and Planning Strategies
Authored by James Hamill
About this Course
Topics covered include: Applicability of self-employment tax to partnership income, including LLC members; The economic effect test for respecting partnership allocations; Allocations of partnership nonrecourse deductions; Section 704(c) allocations of built-in gains and losses; Determining partner's shares of recourse and nonrecourse debt; Sales and exchanges of partnership interests; Section 743 adjustments to basis for a purchasing partner; Tax treatment of distributions of money and property; Section 734 basis adjustments for partnership distributions; The impact of the Tax Cuts and Job Creation Act of 2017; Overview: Impact of Section 199A deduction; Overview: Centralized Audit Rules; Partner SE Tax Issues; Partners' Distributive Shares; Partners' Shares of Liabilities; Sales and Exchanges of Interests; Partnership Distributions; Partnership Terminations.
Upon completing this course, you should be able to: Describe essential areas in partnership taxation; Identify tax planning opportunities and partnership pitfalls; Describe types of income subject to partner self-employment tax based on general rule; Identify LLC member self-employment tax;
Recognize guaranteed payments; Identify exceptions to the general rule that the agreement controls, with respect to a partners' distributive shares; Differentiate statements regarding the substantial economic effect principles; Recognize the three requirements with respect to the economic effect safe harbor; Describe what Section 704(c) deals with; Identify methods for partnership allocation identified in the regulations prescribes that the cure must be an item of similar character; Describe the steps with respect to the qualified business income deduction; Recognize why debt shares matter; Identify statements with respect to the zero-value liquidation approach; Differentiate statements with respect to the considerations for nonrecourse debt shares; Recognize which type of elections a taxpayer should make in various scenarios; Describe gain recognition of partnership distributions; Differentiate correct statements regarding loss recognition of partnership distributions; Describe Section 734 adjustments; Identify safe harbor and disguised sale considerations; Recognize how many years of contribution should be closely evaluated as a potential disguised sale; Identify requirements for the separate self-employment tax exception related to retirement payments; Describe when an economic effect is substantial; Recognize when the economic effect safe harbors includes an alternate test for economic effect; Identify when the concept of minimum gain applies; Describe when pre-contribution gains and losses are not related to a partnership; Identify methods for partnership allocation; Recognize the approach a partnership distribution generally follows; Describe the result of losses from a partnership distributions.