Understand the rules governing partnership allocations and the commercial import of choices and elections that can be made.
Partnerships and limited liability companies are among the most common business entity types in the United States. They are prized for their 'flow-through' tax benefits for both large and small businesses. However, the tax rules governing the allocation of partnership income and loss are among the most technical, complex, and commonly misunderstood in the Internal Revenue Code, resulting in unintended tax consequences. This presentation will help tax and business professionals better understand the rules governing partnership allocations and the commercial import of choices and elections that can be made within those rules.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Capital Accounting
- Significance of Capital Accounts
- Substantial Economic Effect
- Partners' Interests in the Partnership
704(c) Considerations
- 704(c) Goals
- 704(c) Methodologies
- Reverse 704(c) Considerations
Partnership Agreement Allocation Approaches
- Safe Harbor Allocations
- Targeted Capital Accounts
Frequently Negotiated Issues
- Calculating Tax Distributions
- 704(c) Methodologies
Questions and Answers
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on January 18, 2023.
Call 1-866-352-9540 for further credit information.
- AIPB 2.0
- This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
- AR CLE 1.5
- This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
- Arizona CLE 1.5
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.5
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
- CT CLE 1.5
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
- GA CLE 1.5
- This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.5 CLE hours.
- MO CLE 2.0
- This course qualifies for self-study CLE credit in Missouri.
- NH MCLE 1.6
- NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 101 Minutes.
- RI CLE 2.0
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 2.0 hours of CLE credit.
- VT CLE 1.5
- This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Michael P. Spiro
Finn Dixon & Herling LLP
- Partner and Tax Group Chair, Finn Dixon & Herling LLP
- Practice emphasizes tax planning for domestic and international transactions including, mergers and acquisitions, growth equity investments, leveraged finance, and private equity and hedge fund formation
- Frequent speaker for the New York State Society of CPAs, Foundation Research Associates Hedge, and Private Equity Fund Tax Seminars
- Frequently published author
- Member of the Connecticut Bar Association Tax Section Executive Committee, American Bar Association
- J.D. degree, University of Pennsylvania; LL.M. degree in taxation, Temple University; B.A. degree, Brandeis University
- Can be contacted at [email protected] or 203-325-5067
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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