The rules outlined in 199A regarding partnerships are complex, including the allocation of gain, loss, depreciation, recourse and non-recourse liabilities, contributed and distributed property and other tax attributes. The need for tax professionals with specialized training to understand the tax planning opportunities and pitfalls that these rules present has never been greater. In this in-depth program, you will work through over 100 examples and use real-world case studies to discover how you can apply key concepts to your clients’ benefit. You’ll acquire the knowledge and confidence you need to effectively handle and provide advice on partnership issues.
Overview of all of Subchapter K but greater emphasis on: Section 704(b)- substantial economic effect including special allocations. Section 754 election- yes or no? Basis adjustment upon sale of a partnership interest. Basis adjustments upon the death of a partner. Basis adjustments upon distribution of property to a partner. Basis adjustment upon redemption of a partnership interest. Allocation of a basis adjustment- section 755. Mandatory basis adjustment rules- sections 734(d) and 743(d). Appreciated inventory and unrealized receivables- hot assets. Impact of hot assets on current and liquidating distributions. Impact of hot assets on sale or redemption of partnership interests. Contribution of property to a partnership- section 704( c ). Review of methods allowed re section 704( c ). Disguised sales. Reporting requirements.
Review partnership tax rules by reviewing the code, the regulations and key relevant cases.
Mr. Born, a Certified Public Accountant, received a Bachelor of Science degree in Electrical Engineering and a Masters of Business Administration degree from the University of Washington.
While obtaining his MBA degree, he was employed by the Boeing Company. After obtaining his MBA degree, he joined KPMG Peat Marwick where be ultimately became a tax partner. He left Peat Marwick to become a real estate entrepreneur but continued to practice federal income tax.
After a successful career as a real estate entrepreneur, Mr. Born expanded his tax practice consulting with other CPAs relating to their more challenging tax questions primarily relating to real estate, partnership and advanced personal tax planning.
Mr. Born is the recipient of the Elijah Watt Sells silver medal award for the second highest grades in the United States on the CPA examination.
Mr. Born is an experienced educator who both writes and teaches tax courses for the Washington Society of Certified Public Accountants and teaches Masters of Taxation courses at Golden Gate University. Mr. Born also is an experienced speaker primarily on tax subjects including five presentations at the Northwest Tax Institute.
Non-Member Price $670.00
Member Price $570.00