Description

As staff members gain more experience, they are expected to take on more complex assignments with minimal supervision. This course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation. The material provides a deep 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 §754 on transfers of ownership interest, distributions, self-employment tax issues, and termination and liquidations of an LLC. With a blend of legal and tax ramifications regarding LLC-specific issues, this course identifies all the major areas that are potential sources of increased complexity.

Instructor: Sue Smith, CPA

Target Audience

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

Course Objectives

Prepare complicated partnership returns

Understand certain advanced concepts of partnership taxation

Subjects

Reporting requirements for Schedules K-2 and K-3

Capital account reporting requirements

Schedule K-1 reporting for §743 adjustments

Schedule K-1 reporting for §704 gains and losses

Comprehensive case on partnership/partner application of the business interest deduction

Section 704(b) basis versus tax basis for capital accounts

Detailed rules of §704 for preventing the shifting of tax consequences among partners or members

Unreasonable uses of the traditional and curative allocation methods

Layers of §704(c) allocations

Treatment of recourse versus nonrecourse debt basis

How to calculate basis limitations and the implications on each partner’s own tax return

How §179 limitations affect partnership/LLC basis

Regulations for handling basis step-ups under §754 elections and mandatory adjustments under §743 and §734 for partnerships that have not made a §754 election

Subsequent contributions of property with §754 adjusted basis to another partnership or corporation

Capital account adjustments in connection with admission of new members

Special allocations and substantial economic effect

LLCs and self-employment tax to members

Distributions – current or liquidating, cash or property, and the substituted basis rule

Termination and liquidation of an LLC

Prerequisites

Knowledge and experience in business taxation