Advanced Tax Strategies for LLCs and Partnerships / Edition 1 available in Paperback
Advanced Tax Strategies for LLCs and Partnerships / Edition 1
- ISBN-10:
- 1119512395
- ISBN-13:
- 9781119512394
- Pub. Date:
- 04/17/2018
- Publisher:
- Wiley
Advanced Tax Strategies for LLCs and Partnerships / Edition 1
Paperback
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$94.50Overview
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
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Table of Contents
Chapter 1 1-1Allocation of Partnership and LLC Income Under Section 704(b) 1-1
Economic Effect: The General Test 1-3
Deemed Economic Effect 1-13
Alternate Test for Economic Effect 1-14
Substantiality 1-18
Denied Allocations: Deter 1-23
Other Issues 1-26
Allocation of Deductions Attributable to Nonrecourse Debt 1-31
Summary 1-35
Chapter 2 2-1
Allocations With Respect to Contributed Property: Section 704(c)(1)(A) 2-1
The Traditional Method 2-4
The Traditional Method With Curative Allocations 2-13
The Remedial Allocations Method 2-16
Special Rules 2-21
Summary 2-24
Chapter 3 3-1
Allocation of Partnership Recourse Liabilities Under Section 752 3-1
How Liabilities Affect Partner Tax Consequences 3-2
Allocation of Liabilities Among the Partners: In General 3-12
Allocation of Recourse Liabilities 3-15
Chapter 4 4-1
Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b) 4-1
Distinguishing Between Recourse and Nonrecourse Liabilities 4-2
Allocation of Nonrecourse Debts 4-7
Treatment of Contingent Liabilities 4-16
Chapter 5 5-1
Advanced Distribution Rules 5-1
Non-Liquidating Distributions Generally 5-2
Distribution of Multiple Properties 5-7
Summary 5-20
Chapter 6 6-1
Adjustments to the Basis of Partnership or LLC Assets 6-1
Section 743: Adjustments Following the Transfer of a Partnership Interest 6-3
Distributions of Partnership Property 6-6
Allocating the Adjustment Amount Among Partnership Properties 6-16
Chapter 7 7-1
Sale of an Interest in a Partnership or LLC 7-1
General Tax Consequences Associated With Sale 7-2
“Hot” Assets and Section 751(a) 7-6
Collectibles and Unrecaptured Section 1250 Gain 7-11
Installment Sales 7-13
Net Investment Income Tax 7-15
Sale of an Active (Non-passive) Interest in a Partnership or LLC 7-16
Sale of a Passive Interest in a Partnership or LLC 7-18
Potential for Termination of the Partnership 7-19
Consequences to the Purchaser 7-25
Tax Glossary Tax Glossary 1
Index Index 1
Solutions Solutions 1
Chapter 1 Solutions 1
Chapter 2 Solutions 4
Chapter 3 Solutions 6
Chapter 4 Solutions 9
Chapter 5 Solutions 12
Chapter 6 Solutions 15
Chapter 7 Solutions 18