As they gain more experience, staff are expected to take on more complex assignments with minimal supervision. The course is designed to be a stepping stone for staff interested in pursuing more advanced partnership and LLC issues than mere preparation, via deeper life-cycle study into critical areas of formation, special allocations of income and deductions, basis calculations and implications of recourse and nonrecourse debt, basis step-up under 754 on transfer of an ownership interest, distributions, selfemployment tax issues, and termination/liquidation of the LLC.
Experienced CPAs desiring a comprehensive case approach to understand reasonably complex limited liability company issues and problems; also, CPAs who want a comprehensive, intermediate-level limited liability company practice manual
Learning Objectives: Prepare more complicated partnership returns Understand certain advanced concepts of partnership taxation Complete the second stage of a graduated professional education program in servicing partnership and LLC clients
Major Topics: Taking initiative in difficult assignments; can you deliver the QBI message? Full coverage of 199A qualified business income, its calculation, limitations, and examples When to use "704(b) basis" for capital accounts versus "tax basis" Detailed rules of 704 for preventing the shifting of tax consequences among partners or members Unreasonable uses of the traditional & curative allocation methods Multiple layers of 704(c) allocations Treatment of recourse versus nonrecourse debt basis How to calculate basis limitations and their implication on each partner's own tax return How 179 limitations affect partnership/LLC basis Regulations for handling basis step-ups under 754 elections, and mandatory adjustments under 743 and 734 for partnerships who have NOT made the 754 election Subsequent contributions of property with 754 adjusted basis to another partnership or corporation Capital account adjustments in connection with admission of new member Special allocations require "substantial economic effect"; what are the requirements? LLCs and self-employment tax to the members Distributions -- current or liquidating, cash or property including the substituted basis rule Termination/liquidation of an LLC
Knowledge and experience in partnership taxation
Massachusetts Society of CPAs 105 Chauncy Street, 10th Floor,
Boston, MA 02111