Understanding Partnership Taxation: Debt Allocations
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Virtual
2.00 Credits
Member Price $109.00
Non-Member Price $189.00
Overview
You could pay $0 for this course!
This course qualifies for EA/IRS and CFP credit. If you need EA/IRS credit, please contact Tyler Dion (tdion@masscpas.org) after you have registered and provide him your PTIN number.
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.
This course qualifies for reimbursement through the state’s Workforce Training Express Fund. Firms/companies with fewer than 50 staff can be reimbursed up to 100% of the cost of training and firms/companies with 50-100 employees can be reimbursed up to 50% of the cost of training. You must register for the course and apply for reimbursement through the Workforce Training Express Fund website a minimum of three weeks prior to the start of the course. The course code for this program is C-13020. To learn more, click here or contact Julia Ekelund at jekelund@masscpas.org.
Highlights
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
Designed For
Tax practitioners who are looking to improve their knowledge of debt allocations and how they affect a partner’s tax basis
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
Preparation
None
Leader(s):
Leader Bios
Joseph Nicola, Surgent McCoy CPE LLC
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.
Non-Member Price $189.00
Member Price $109.00