Advanced Partnership Taxation Concepts (Currently Unavailable)

Author: Greg White

Partnerships are the fastest growing type of business entity. Understanding the finer points of tax preparation and planning for partnerships is a key part of all tax practices. In this course, we’ll cover sophisticated strategies to keep you on the cutting edge, including self-employment tax for LLC members, allocating losses of limited liability companies, and admitting new partners in the most tax efficient manner.

Publication Date: December 2020

Topics Covered

• Introduction & General Topics
• Partnership Definition: Luna v. Commissioner
• Rev. Proc. 2002-69 and §761(f): Toggle On and Off Spousal Partnerships
• Trends in Choice of Entities
• LLC's are Great for Real Estate Rentals
• Bonus Depreciation: Final Regulations
• Land Improvements
• Sales of Partnership Interests
• Allocations: Land, Building, Land Improvements Personal Property
• §705(b) — Patron Saint of Lost Records
• Debt-Financed Distributions: When a Partnership Refinances
• LLC Members SE Tax
• Final Regs: CPAR "Imputed Underpayment"
• Off-Ramp 1-3
• Service Businesses: Changing of the Guard
• "Adjusting" Basis for Distributions: §734
• Admission of New Partners (Profits Interests)
• The "Goldilocks" Method
• Allocating Income and Losses: Partners and LLC Members
• LLC's: Alternate Test for Economic Effect
• Partners' Interests in the Partnership
• Tax Follows Economics
• Loss Allocations
• Economic Equivalence Test: The Dumb-but-Lucky Approach
• §199A QBID — Planning for LLCs
• QBID: Changing Our View of LLCs vs. S Corps
• Planning: Guaranteed Payments
• Unreimbursed Expenses
• Surprise: §179 Taxable Income Limit Includes Guaranteed Payments
• PPP Expenses: Deductibility for Partners

Learning Objectives

• Determine most tax efficient manner of admitting new partners
• Identify LLC members who are subject to self-employment tax
• Describe a consideration with respect to determining whether a partnership exists based on the Luna case
• Differentiate which court case was overturned on appeal due to a procedural matter
• Describe correct statements regarding the trends in the type of entity from 1995 to 2013
• Identify the steps in the purchase and sale of real estate
• Recognize which IRS form an entity that seeks to elect out of the CPAR requirements entirely may do so by appropriately filing should use
• Describe which referenced tax sections was compared to online dating
• Recognize which income allocation method does not require unlimited DRO
• Identify the full phase in amount related to the QBI deduction for single filers in 2020
• Identify the most common and most effective type of partnership payment
• Identify the number of ways to allow spouses to avoid partnership treatment
• Identify the starting point with respect to §705(b)
• Identify the exit ramps with respect to CPAR
• Describe types of SSTBs
• Identify the phase-in range for married filing jointly taxpayers with respect to QBID
• Identify a method of allocation between land and building

Level
Advanced

Instructional Method
Self-Study

NASBA Field of Study
Taxes (5 hours)

Program Prerequisites
Basic understanding of partnership taxation.

Advance Preparation
None