Surgent's Understanding Partnership Taxation: Debt AllocationsSU0282 24

 

Surgent's Understanding Partnership Taxation: Debt Allocations

January 3rd, 2025 - January 3rd, 2025 @ 10:00AM-12:00PM

Member Price $99
Non-Member Price $129
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Credits

2

Description

How debt is allocated to the partners in a partnership is important. It dictates how much money may be taken tax-free as a distribution, the losses that flow down to the partners, and the gain or loss on the sale of a partnership interest. However, the allocation of debt can differ depending on the type of debt it is and the type of partner we are talking about. Furthermore, 704(c) can complicate things. And what in the world is a constructive liquidation scenario? In this course, we will tackle the concept of debt allocations - how you do it, what it means, and why you do it.

Objectives

  • State how debt allocations affect the calculation of a partner’s basis in the partnership
  • Recognize how recourse and nonrecourse debt are allocated to partners
  • Identify the tax effects of 704(c) on contributed property

Major Subjects

  • Recourse debt allocations
  • Constructive liquidation scenarios
  • Nonrecourse debt allocations
  • Minimum gains and nonrecourse deductions
  • Section 704(c) gains
  • Allocations under 704(c)

Prerequisites

Working knowledge of fundamental partnership tax concepts