Section 743(b) Adjustments in Multi-Tier Partnerships: Applying Rev. Rul. 87-115 to Upper- and Lower-Tier Entities
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and compliance professionals with an advanced and practical guide to the reporting complexities and planning opportunities present in making Section 743(b) adjustments in the context of multi-tiered partnerships. The panel will outline the provisions of Rev. Rul. 87-115 governing when an upper-tier partnership may push 743(b) adjustments down to lower-tier partnership's assets, discuss planning opportunities under various scenarios, and detail the Section 755 adjustments required when making 743(b) adjustments in lower-tier partnerships.
Outline
- Section 754 election and interaction between Sections 754-755
- Transactions giving rise to adjustments under Sect. 743(b)
- 743(b) basis adjustment rules for multi-tier structures under Rev. Rul. 87-115
- When both UTP and all LTPs have valid Section 754 election in place
- When only the UTP has made a valid Section 754 election
- When only the LTP has made a valid Section 754 election
- Coordinating tax reporting between UTP and LTPs
- Segregating individual transactions subject to Section 743(b) allocations
- Planning opportunities under various scenarios
Benefits
The panel will review these and other key issues:
- Mechanics of applying 743(b) basis adjustments with various combinations of partnership tiers having Section 754 elections in place
- Allocation of basis adjustments to upper- and lower-tier partnerships
- Reporting requirements and challenges in preparing the Form 1065 return for the upper-tier partnership
- Planning opportunities under various scenarios addressed in Rev. Rul. 87-115
Faculty
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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Tanner Yeates
Partner
Holthouse Carlin & Van Trigt
Mr. Yeates has over a decade of experience providing tax consulting, compliance and structuring services and... | Read More
Mr. Yeates has over a decade of experience providing tax consulting, compliance and structuring services and specializes in serving clients structured as pass-through entities, primarily in the private equity and real estate industry sectors. He specializes in providing partnership tax consulting and compliance services. Mr. Yeates' experience includes addressing Hypothetical Liquidation at Book Value accounting, tax modeling, accounting for partnership basis adjustments, waterfall calculations, and other multi-tiered partnership tax issues. He has extensive experience performing financial modeling for complex transactions. Mr. Yeates focuses on the analysis of the tax efficiencies of proposed deal structures and conducts comprehensive tax due diligence.
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