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What works best for clients? Learn the pros and cons of the LLC,
general partnership, limited partnership, and limited liability
partnership by focusing on planning and potential tax traps. This
title offers a review of distinct advantages of these entities
coupled with an examination of the risk members and partners face
if they do not have a solid tax plan to minimize their exposure. In
addition, the authors explore some of the more intricate rules and
regulations of these entities so you can move your working
knowledge of partnership and LLC taxation beyond the basics. This
book prepares the reader to do the following: Analyze a partnership
or LLC agreement to determine whether any special allocations in
the agreement will be allowed under Code Section 704(b) Identify
the potential economic consequences of special allocations to a
partner or LLC member Identify the potential tax consequences when
a partner or LLC member has a negative balance in his or her
capital account Recognize the relationship between partnership and
LLC allocations of profit and loss and the allocation of the risks
and rewards of entity operations Distinguish between the
requirements for substantiality and those for economic effect under
the regulations Distinguish between "book" allocations required
under Section 704(b) and "tax" allocations required under Section
704(c) Recognize the three methods described in the Section 704(c)
regulations to make special allocations with respect to contributed
property Determine when a non-contributing partner or LLC member
will or will not be protected by required allocations under Section
704(c) Calculate the gain that can result from reallocation of
liabilities when a partner joins a partnership Calculate a
partner's or member's share of recourse liabilities of a
partnership or LLC Distinguish between recourse and nonrecourse
liabilities of a partnership or LLC Analyze the impact of a partner
or LLC member's guarantee of a recourse or nonrecourse liability of
the entity Recognize when to treat a liability as a recognized
versus contingent liability and understand how to account for
partnership or LLC contingent liabilities Calculate the basis of
each property received by a partner receiving multiple properties
in a liquidating vs. non-liquidating distribution from a
partnership or LLC Recognize which properties will receive a
step-up or step-down in basis when multiple properties are received
from a partnership or LLC Allocate basis increases or decreases
among multiple properties for federal income tax purposes Determine
when an Internal Revenue code (IRC) Section 754 election will allow
a partnership or LLC to adjust its basis in its assets Allocate
required basis adjustments among partnership or LLC assets
Determine the tax consequences associated with the sale of a
partner's or member's interest in a partnership or LLC Recognize
how using the installment method to account for the sale of a
partnership interest will affect how the partner will report his or
her gain on the sale Recognize when the sale of an interest in a
partnership will trigger a technical termination of the partnership
Determine the tax basis and holding period of assets owned by the
partnership following a technical termination Determine the tax
consequences associated with subsequent dispositions of built-in
gain or loss assets following a technical termination
Are you ready to master the advanced concepts of partnership
taxation? Provide your clients with valuable advice and tax
planning strategies and gain a working knowledge of the Internal
Revenue Code's sophisticated partnership tax rules and regulations.
This book takes a deep dive into the complexities of partnership
tax law. It includes step-by-step examples to help guide you
through the complicated world of advanced partnership and LLC tax
law. Some of the many concepts covered in this course include
special allocations, liquidating and non-liquidation distributions,
property basis calculations under various scenarios, and sales of a
partnership interest.
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