Advanced Partnership Issues-Featuring the New Partnership Audit Regime and Tax Cuts and Jobs Act Changes (APIA)

Tuesday, August 20, 2019 from 8:00 AM to 3:30 PM in Sioux Falls

8.00 CPE Credit Hours

As we bid farewell to the TEFRA consolidated audit rules, we face the brave new world of the completely revised partnership audit regime. This takes effect with partnership years beginning in 2018. Partnerships and their advisers need to understand how these new rules radically change the nature of partnership examinations and the likely future impact on the structure of partnerships. All of this adds to the inherent complexity of partnerships, including partnership allocations (including targeted capital account based allocations), the required allocations for contributed property under 704(c) and more, areas this course will cover to held advanced practitioners deal with the practical problems faced by their partnership clients.
Designed For
CPAs, accountants, and financial professionals who advise their clients regarding planning for partnership and/or limited liability company transactions and/or who have review responsibility for partnership or limited liability company tax compliance.
Objective

Participants will be able to:

  • Recognize issues that will arise under the newly revised consolidated partnership audit regime, as well as partnerships that will be eligible of opt-out of the regime
  • Calculate the special allocations required for Section 704(c) property
  • Understand partnership capital accounts and be able to explain to clients why they are important
  • Deal with the implications on allocations for agreements written with targeted capital accounts
  • Handle Section 754 elections and related adjustments
  • Apply rules properly when passing income and other items through to owners
  • Deal with the IRS's recent aggressive approach to dealing with self-employment income from LLCs and similar entities
  • Apply the special three year holding period rules for partners with carried interests
Highlights
  • The new partnership audit rules that were part of the Bipartisan Budget Act of 2015
  • IRS guidance on the new audit rules, including proposed regulations as well as any Congressional revisions that take place in the current year
  • Liabilities and their allocation to owners' basis-Sec. 752
  • Determination of owners' distributive share including special allocations-Sec. 704(b)
  • Adjustments for contributed property-Sec. 704(c)
  • Optional adjustments to the basis of entity property-Section 754 election
  • Distribution of "HOT" assets-Sec. 751
  • Payments to a retiring partner or member-Sec. 736
  • Carried interest three year holding period-Sec. 1061
  • Current developments-Court cases and IRS rulings
Prerequisites
Experience advising clients on tax matters
Advanced Preparation
None
Developer
Loscalzo
Presenters
Ed Zollars,
Level of Knowledge
Advanced

Course Location

EideBailly LLP
200 E 10th St #500
PO Box 5125
Sioux Falls, SD 57104

Member

$270.00

Late
Registration *

$320.00

Non-Member

$320.00

Late
Registration *

$370.00

* If postmarked after 7/29/2019
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