Section 754 Step-Up in Basis: Tax Issues for Part. & LLCs Web. [S754]

Aug 25, 2021
Time: 12:30pm - 2:15pm

Subject:

Taxation

Credit Hours:

2.00

Price:

Member: $75.00
Non-member: $112.50

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Discussion Leader:

Joseph Nicola, CPA    more info

Joe Nicola is a Tax Partner with more than thirty-five years of experience in public accounting. Joe has experience in many diverse areas of taxation, including the taxation of and planning for individuals, family offices, and various forms of business entities, such as corporations, partnerships, and limited liability companies. Joe is particularly experienced in federal and multi-state tax matters that affect numerous industries and niches, including private equity, investments, natural resources, manufacturing, distribution, high technology, securities, and start-up businesses. He has consulted on technically complex matters, such as retirement planning, succession planning in the context of a family office, securities, partnership and corporate reorganizations and liquidations, and international tax matters. While in public practice, Joe also served for many years as an adjunct member of the faculty with Duquesne University's MBA and Master of Science in Taxation/Accountancy programs, as well as with Robert Morris University's Master of Taxation program. His course load included Corporate Taxation, Advanced Corporate Taxation, Reorganizations (Mergers and Acquisitions), Taxes as a Basis of Managerial Decisions, and Taxation of Derivatives. He is also a published author of CPE/CLE texts and industry articles, and a frequent professional speaker. Mr. Nicola received his BS degree in Business Administration from Robert Morris University and his JD degree from the University of Pittsburgh School of Law.

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Website registration for this course closes on August 24, 2021. To register after this date please contact the society at akcpa@ak.net or 907-562-4334.

Full Description

Section 754 Step-Up in Basis: Understanding the Tax Issues for Partnerships & LLCs Webcast (S754)

August 25th, 2021

When a purchaser buys an existing partners partnership interest or the interest of a member of a limited liability corporation (LLC) taxed as a partnership, the amount paid becomes the basis for the purchasers partnership interest (outside basis). If the partnerships assets have appreciated sufficiently, the difference between the new partners inside and outside basis can be substantial. This disparity can deprive the new partner of depreciation deductions and inflate his or her share of the gain from subsequent property dispositions unless a Section 754 election is in effect. The Section 754 election can also apply when a partnership makes a distribution of property and the basis of the distributed property to the partnership and the basis the partner/distributee will take in the distributed property are not equal. In this case, a partnership can recover basis it would otherwise lose if the 754 election were not in effect.

Major Topics Covered:
-How and why a partnership makes a 754 election
-The effect of the 754 election when an interest in a partnership is sold or inherited
-How the 754 election applies when a partnership makes a distribution of property to one or more of its partners
-How to make the 754 basis adjustment

Learning Objectives:
-Determine the amount of a Section 754 basis step-up
-Know how to allocate the basis step-up to the partnership's assets
-Know how a partnership makes a Section 754 election and reports it to the IRS

Designed For: Any tax practitioner who wishes to understand the tax rules and economic opportunities associated with having a partnership make a Section 754 election.

CPE Credits: 2, Taxation

Level of Knowledge: Intermediate

Prerequisite: A basic understanding of the tax rules impacting individuals and pass-through entities.

Acronym: S754

Discussion Leader: Joseph Nicola, CPA