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As we bid farewell to the TEFRA consolidated audit rules, we face the brave new world of the completely revised partnership audit regime. This takes effect with partnership years beginning in 2018. Partnerships and their advisers need to understand how these new rules radically change the nature of partnership examinations and the likely future impact on the structure of partnerships. All of this adds to the inherent complexity of partnerships, including partnership allocations (including targeted capital account based allocations), the required allocations for contributed property under 704(c) and more, areas this course will cover to help advanced practitioners deal with the practical problems faced by their partnership clients.

Objectives

Participants will be able to:

  • Recognize issues that will arise under the newly revised consolidated partnership audit regime, as well as partnerships that will be eligible of opt-out of the regime
  • Calculate the special allocations required for Section 704(c) property
  • Understand partnership capital accounts and be able to explain to clients why they are important
  • Deal with the implications on allocations for agreements written with targeted capital accounts
  • Handle Section 754 elections and related adjustments
  • Apply rules properly when passing income and other items through to owners
  • Deal with the IRS's recent aggressive approach to dealing with self-employment income from LLCs and similar entities
  • Apply the special three year holding period rules for partners with carried interests

Highlights

  • The new partnership audit rules that were part of the Bipartisan Budget Act of 2015
  • IRS guidance on the new audit rules, including proposed regulations as well as any Congressional revisions that take place in the current year
  • Liabilities and their allocation to owners' basis-Sec. 752
  • Determination of owners' distributive share including special allocations-Sec. 704(b)
  • Adjustments for contributed property-Sec. 704(c)
  • Optional adjustments to the basis of entity property-Section 754 election
  • Distribution of "HOT" assets-Sec. 751
  • Payments to a retiring partner or member-Sec. 736
  • Carried interest three year holding period-Sec. 1061
  • Current developments-Court cases and IRS rulings

Who Will Benefit

CPAs, accountants, and financial professionals who advise their clients regarding planning for partnership and/or limited liability company transactions and/or who have review responsibility for partnership or limited liability company tax compliance.

Credits

Category Amount
Tax 8.00
Printed Materials must be ordered at least ten days prior to the start of the class.
Yikes, the time is near. Please call NMSCPA at (505) 246-1699 to register.

Leaders

  • Edward Zollars

    Edward K. Zollars, CPA, is in public practice in Phoenix, Arizona as a partner with the firm of Thomas & Zollars & Lynch, Ltd. He has been in practice for over twenty five years, specializing in tax issues for closely held businesses and individuals. Ed has been professionally involved with both tax and technology issues, combing the two disciplines in starting the first tax podcast (Ed Zollars Tax Update, produced weekly dealing with current tax issues. He has been a member of AICPA Tax Division Committees dealing with tax and technology issues, and was the Tax Section’s representative on three occasions to the AICPA’s Top Ten Technologies project. Ed is also a member of the Phoenix Tax Workshop’s Advisory Committee, and currently serves on the Tax Legislation Liaison Committee for the Arizona Society of CPAs. Ed was selected as a Life Member by the Arizona Society of CPAs in May of 2010. Ed is a co-author of the Arizona Income Tax Guide published by the Phoenix Tax Workshop, and has written articles published in Practical Tax Strategies and the Tax Adviser. He has been a frequent contributor to a number of professional tax discussion groups, and served as systems operator on the AICPA’s Accountants Forum in the mid 1990s. He has spoken regularly on tax and technology topics since 1996, speaking before conferences sponsored by the AICPA and a number of state society of CPAs.

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