20SS-0219: Surgent's Partnership and LLC Core Tax Issues From Formation Through Liquidation (Self-Study)

Valid for one year from purchase date
Self-study - Downloadable PDF
8 CPE (8 technical)  |  8 IRS CE

As they gain more experience, staff are expected to take on more complex assignments with minimal supervision. The course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation, via deeper 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 Section 754 on transfer of an ownership interest, distributions, self-employment tax issues, and termination/liquidation of the LLC.

Major subjects

• Discuss new pass-through basis calculations required as attachments to certain individual returns
• Excess Business Losses and new rules for NOLs
• Comprehensive case on partnership/partner application of the Business Interest Deduction
• When to use "704(b) basis" for capital accounts versus "tax basis"
• Detailed rules of Section 704 for preventing the shifting of tax consequences among partners or members
• Unreasonable uses of the traditional & curative allocation methods
• Multiple layers of Section 704(c) allocations
• Business situations & partnerships that qualify; others that do not
• Treatment of recourse versus nonrecourse debt basis
• How to calculate basis limitations and its implication on each partner's own tax return
• How Section 179 limitations affect partnership/LLC basis
• Regulations for handling basis step-ups under Section 754 elections, and mandatory adjustments under Section 743 and Section 734 for partnerships who have NOT made the Section 754 election
• Subsequent contributions of property with Section 754 adjusted basis to another partnership or corporation
• Capital account adjustments in connection with admission of new member
• Special allocations require "substantial economic effect"; what are the requirements?
• LLCs and self-employment tax to the members
• Distributions -- current or liquidating, cash or property including the substituted basis rule
• Termination/liquidation of an LLC

Learning objective(s)

• Prepare more complicated partnership returns
• Understand certain advanced concepts of partnership taxation

Who should take this program?

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

Fees

Standard Member Fee	$125.00
Standard Nonmember Fee	$125.00