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IRC 754 Elections for Tax Counsel: Mastering Structuring Considerations of Basis Adjustments

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Thursday, April 10, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, March 14, 2025

or call 1-800-926-7926
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This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and partnership interests or property distributions; review the impact of the Section 754 election for individual partners and the partnership; and discuss structuring transactions to avoid unintended tax consequences.

Description

Understanding the Section 754 election and its related basis adjustments is a critical skill for tax counsel serving as advisers to clients owning or managing partnerships. The election allows adjustments on the "inside basis" of assets the partnership owns.

The basis adjustment can have a significant impact when a partnership has an existing 754 election and admits a new partner, has one partner sell a partnership interest, or when the partnership makes a distribution to a partner. The election and adjustments can have different impacts on different partners, so tax advisers need to fully grasp the tax implications of making the election and utilizing the optional basis adjustments.

Tax advisers must understand not only the rules but also the practical calculations, allocations, and reporting mechanics of the 754 election. Counsel may be called upon to help make essential decisions with basis and depreciation issues and to help make complicated adjustment calculations.

Listen as our authoritative panel of tax advisers guides counsel through the basis adjustment rules, discusses the impact of the Section 754 election on individual partners and the partnership, and provides best practices for avoiding potential pitfalls of the election.

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Outline

  1. The mechanics of a Section 754 election
  2. Inside and outside basis issues
  3. Ability to make 754 election due to a transfer
  4. What happens under 743(b) when a 754 election is made?
  5. 755 Basis adjustments
  6. Benefits

Benefits

The panel will review these and other key issues:

  • Mechanics of making a Section 754 election at the partnership level and understanding "inside basis" vs. "outside basis"
  • Benefits and disadvantages of making the 754 basis election
  • Rules governing step-up and step-down basis adjustments
  • Rules for allocating basis adjustments
  • Impact of the 754 election on individual partners and the partnership
  • Common pitfalls in basis adjustments, and what practitioners can do to avoid these pitfalls

Faculty

Mandarino, Joseph
Joseph C. Mandarino
Partner
Smith Gambrell & Russell

Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of...  |  Read More

Additional faculty
to be announced.
Attend on April 10

Early Discount (through 03/14/25)

See NASBA details.

Cannot Attend April 10?

Early Discount (through 03/14/25)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video