IRC Section 734 Adjustments for Section 754 Elections: Distributing Partnership Property
An Advanced Case Study of Calculations and Considerations
Recording of a 110-minute CPE webinar with Q&A
This course will equip tax professionals with the tools to analyze the impact of a Section 754 election (or lack thereof). The panel will offer a detailed case study and illustration of how to calculate Section 734(b) basis adjustment(s) to assets retained by the partnership after distribution to a partner.
Outline
- The mechanics of a Section 754 election
- Basis adjustments under Section 734(b)
- Negative adjustment
- Positive adjustment
- Allocation of adjustment under IRC 755
- Special rules - 163(j), 168(k), 199A, and other considerations
- Case study and illustration
- Planning considerations
Benefits
The panel will review these and other principal issues:
- Making a Section 754 election at the partnership level and understanding "inside basis" vs. "outside basis"
- Understanding the basis adjustment under Section 734(b)
- Calculating Section 734(b) adjustment on retained partnership assets
- Allocating Section 734(b) adjustment to a partnership's remaining assets
- Reporting Section 734(b)adjustments
- Planning considerations and consequences of Section 734(b) adjustments
Faculty
Marcus E. Dyer, CPA, JD
Principal, Team Leader of Tax Controversy
Withum Smith+Brown
Mr. Dyer manages and reviews all aspects of federal and state tax compliance for C-corporation, S corporation and... | Read More
Mr. Dyer manages and reviews all aspects of federal and state tax compliance for C-corporation, S corporation and partnership returns, including consolidated C-corporation returns. He advises businesses on a wide array of tax matters including but not limited to reorganizations and employee benefits. He manages and reviews all aspects of the preparation of high net worth individual returns and conducts tax research on federal and state tax issues. He also handles tax controversies, including at the examination, appeals and collections stages.
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Dean L. Surkin, JD, LLM
Professor (Adjunct)
Pace University Graduate School of Business
Mr. Surkin is an attorney engaged in private practice in the New York metropolitan area. He recently retired from the... | Read More
Mr. Surkin is an attorney engaged in private practice in the New York metropolitan area. He recently retired from the position of Tax Director at a regional CPA firm based in New York City. Prior to that, Mr. Surkin was a partner at Surkin & Handlin, a boutique firm that handled real estate and tax matters. He is a tax attorney with broad-based experience in tax planning and research, has litigated major cases in the fields of taxation, probate and general commercial matters, and has been peer-reviewed by Martindale-Hubbell. Mr. Surkin holds the highest rating for legal ability and ethical standards, AV. His published articles on tax law have appeared in peer-reviewed journals, practitioners’ journals, and the popular press. Mr. Surkin also writes science-fiction short stories about the adventures of his granddaughters and their dog visiting historic events in their uncle’s time machine (their uncle is also a dog) and serves on the Board of Directors of the Westchester Community Orchestra.
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