ACPEN Signature: 2017 LLCs & Partnerships Update

The start date for this course has passed. Registration is no longer available.

This course is 8.00 credits
Field of Study
Tax
Course Level
Update
Vendor
BPN, Inc ACPEN

Registration Fees

MSCPA-AICPA Member
$195.00
MSCPA Member
$195.00
AICPA Member
$245.00
Non-Member
$245.00
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Thursday, Jan 4, 2018
2:00pm – 10:00pm

IRS Form 1065 continues to be a challenge and mistakes are frequently made. Our panel will review the form and explain how common errors can be avoided. In particular, our panel will review the basis and allocation rules where many errors are made and assist you by reviewing common partnership provisions that affect allocations. The Bipartisan Budget Act of 2015 changed partnership audits forever. TEFRA audit rules are being replaced that impose tax liability at audit at the partnership level even though the partners may have changed, and there is an election to do that now if the partnership elects. Moreover, allocation errors may result in a true partnership level tax. Also, the Tax Matters Partner/Member is being replaced by a Partnership Representative who need not be a partner and can bind the partnership at audit. Even the statute of limitations can go beyond three years. Treasury recently released extensive new regulations on this major change and there are some traps for the unwary. Additionally, the panel will look at the consequences of the purchase and sale of a partnership interest and the effects of a 754 election. While often used, the 754 election seems to be misunderstood in its effect and reporting. There are new, proposed and final regulations under Section 706 for changes in a partner’s interest, complex new proposed regulations under 734(b), changes to the partnership recourse and nonrecourse basis rules under the disguised sale rules, proposed changes to eliminate discounts in family partnership planning and proposed regulations on contributions of built-in loss property. Our panel will provide an overview of these final and proposed changes. Join our panel of experts as they navigate the big new changes in partnership tax planning.

The Treasury Department has proposed new Regulations designed to eliminate discounts in family partnerships. Meanwhile, the new Republican Congress and Trump Administration are considering estate tax repeal while possibly keeping a gift tax.  You will need to be up to date to determine whether a family partnership continues to make sense for your client.  Are you losing an income tax basis step-up?  What do you need to change? Does the partnership need to be unwound?

The Bipartisan Budget Act of 2015 will soon change partnership audits forever. TEFRA audit rules are being replaced that impose tax liability at audit at the partnership level even though the partners may have changed, and there is an election to do that for 2016 returns if the partnership elects. The Tax Matters Partner/Member is being replaced by a Partnership Representative who need not be a partner but who can bind the partnership at audit. Even the statute of limitations can go beyond three years. There are numerous elections and traps for the unwary.

Additionally, there are new proposed and final regulations under Section 706 for changes in a partner’s interest and proposed changes to the partnership recourse and non-recourse basis rules.  The basis rules you have known for years have already changed in the case of the disguised sales rules.  Some transactions that once produced no gain will now produce substantial gains. 

And that’s only the highlights as of year-end 2016.  Congress is likely to make substantial changes that impact tax planning using partnerships and LLCs in 2017.

Join our panel of experts as they navigate the big new changes in partnership tax planning.

 

**Please Note:  If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to leighanne.conroy@acpen.com.

 

Designed For

Public Practitioners

Course Objectives

*Understand the new changes in partnership tax planning

*Find out what is new in partnership taxation as of year-end

*Discuss key components and proposed changes in the area of partnership taxation

Major Subjects

*The Bipartisan Budget Act of 2015  

*New proposed and final regulations under Section 706

 

Prerequisites

None

The start date for this course has passed. Registration is no longer available.