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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, April 18, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This course will equip tax professionals with the tools to analyze the impact of a Section 754 election (or lack thereof). The panel will offer a detailed case study and illustration of how to calculate Section 734(b) basis adjustment(s) to assets retained by the partnership after distribution to a partner.

Faculty

Marcus E. Dyer
Principal, Team Leader of Tax Controversy
Withum Smith + Brown, PC

Mr. Dyer manages and reviews all aspects of federal and state tax compliance for C-corporation, S corporation and partnership returns, including consolidated C-corporation returns. He advises businesses on a wide array of tax matters including but not limited to reorganizations and employee benefits. He manages and reviews all aspects of the preparation of high net worth individual returns and conducts tax research on federal and state tax issues. He also handles tax controversies, including at the examination, appeals and collections stages.

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Dean L. Surkin
Professor (Adjunct)
Pace University Graduate School of Business

Mr. Surkin is an attorney engaged in private practice in the New York metropolitan area. He recently retired from the position of Tax Director at a regional CPA firm based in New York City. Prior to that, Mr. Surkin was a partner at Surkin & Handlin, a boutique firm that handled real estate and tax matters. He is a tax attorney with broad-based experience in tax planning and research, has litigated major cases in the fields of taxation, probate and general commercial matters, and has been peer-reviewed by Martindale-Hubbell. Mr. Surkin holds the highest rating for legal ability and ethical standards, AV. His published articles on tax law have appeared in peer-reviewed journals, practitioners’ journals, and the popular press. Mr. Surkin also writes science-fiction short stories about the adventures of his granddaughters and their dog visiting historic events in their uncle’s time machine (their uncle is also a dog) and serves on the Board of Directors of the Westchester Community Orchestra.

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Description

Understanding the Section 754 election and its related basis adjustments is critical for tax professionals serving as advisers to clients owning or managing partnerships. The election allows changes to "inside basis," the bases of assets the partnership owns. Even in the absence of the election, there are mandatory adjustments to inside basis.

Section 734(b) adjustments can have a significant impact when a partnership has a 754 election in effect and makes a distribution to a partner or when a partner has a substantial basis reduction in connection with distribution at a time when the partnership does not have a Section 754 election in effect. Recent changes, including the 163(j) interest limitation, the 199A QBI deduction, and 168(k) bonus depreciation, affect these calculations. Section 734(b) adjustments can have different implications for different partners as well, so tax advisers need to fully grasp the tax consequences of Section 734(b) adjustments.

Tax advisers must understand the rules and grasp the practical calculations, allocations, and reporting mechanics of Section 734(b) adjustments. Failure to understand the "moving pieces" of the basis adjustments under Section 734 can result in unnecessary tax issues for the individual partners--some of whom might be your clients.

Listen as our panel of veteran advisers provides practical guidance in the form of a detailed case study on the ins and outs of the calculation and allocation of Section 734(b) adjustments, leaving you prepared to advise on the planning and compliance tasks in the complex area of partnership taxation.

Outline

  1. The mechanics of a Section 754 election
  2. Basis adjustments under Section 734(b)
  3. Negative adjustment
  4. Positive adjustment
  5. Allocation of adjustment under IRC 755
  6. Special rules - 163(j), 168(k), 199A, and other considerations
  7. Case study and illustration
  8. Planning considerations

Benefits

The panel will review these and other principal issues:

  • Making a Section 754 election at the partnership level and understanding "inside basis" vs. "outside basis"
  • Understanding the basis adjustment under Section 734(b)
  • Calculating Section 734(b) adjustment on retained partnership assets
  • Allocating Section 734(b) adjustment to a partnership's remaining assets
  • Reporting Section 734(b)adjustments
  • Planning considerations and consequences of Section 734(b) adjustments

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Determine whether an IRC 754 election would be beneficial to a partnership and its partners
  • Identify the complex issues for partnerships and partners when sales of interests or property governed by IRC 754 take place
  • Distinguish between IRC 734 and IRC 743 basis adjustment provisions and consequences
  • Recognize when mandatory basis adjustments are required
  • Understand the impact of the IRC 163(j) interest limitation rules
  • Decide whether basis adjustments are correctly calculated

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ mid-level tax experience preparing complex tax forms and schedules, including supervising other preparers and accountants. Specific knowledge and understanding of partnership taxation, IRC 754 elections, IRC 734(b) basis adjustments and allocation of adjustment under IRC 755; familiarity with the election impact on different partners and utilization of optional basis adjustments.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).