Reviewing Partnership Agreements to Identify Key Tax Issues
Authored by James Hamill
About this Course
Topics covered include: Why Review the Agreement?; When to Review the Agreement; Partnership Agreements Is an Extension to a 'Normal' Agreement; What Should We Look For?; Ordering of Analysis- By General Importance; A Basic Approach; Why Distributions First?; Distributions- Do They Match the Deal?; Allocations; How to Evaluate Economic Effect; Profit and Loss Allocations; Too Close a Match between Distributions and Allocations; Distributions Match P&L; Safe Harbor Allocations; Other Terms Used for Profit and Loss Allocations; Varying Interest Allocations; How Do We Know if the Economic Deal Matches the P&L Allocation Provisions?; Target Allocation Issues; Tax Election Issues; Post- 2017 Partnership-Level Audit Regime; Post- 2017 Section 199A Deduction; Specifying a Section 704(c) Method; Lock Out Agreements; Nonrecourse Debt Shares; Grant of a Profits-Only Interest; Pass-Through Entity Taxation.
Upon competing this course' you should be able to:Describe when a review of a partnership agreement by a CPA is recommended; Recognize the economic deal and how to ensure the agreement is consistent; Identify key issues that should be in the agreement for allocation integrity; Describe the common tax provisions and definitions that should be in the agreement; Recognize which Code Section deals with evaluating the economic effect of allocations; Differentiate regulations which include safe harbors for both recourse and nonrecourse allocations; Describe terms for profit and loss allocations; Identify how the CPA should determine if the economic deal in a partnership agreement matches the P&L allocation provisions.