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Understanding Partnership Taxation: Debt Allocations (PTA2)

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2.00 Credits

Member Price $100

Non-Member Price $130

Overview

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.

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

John Kilroy, Surgent McCoy CPE, LLC

John Kilroy is a managing member of iValue Financial Planning LLC, located in the Philadelphia, Pennsylvania area. John engages clients in financial and tax planning, as well as preparing tax returns for individuals, corporations, partnerships, estates, and trusts. John is a CPA and a CFP® practitioner. He is a 1979 graduate of Villanova University with a BS in Accounting. John is a member of the Pennsylvania Institute of Certified Public Accountants and the Financial Planning Association (FPA). Within the FPA, John has served as a board member of the Philadelphia Tri-State chapter and on its education and finance committees. John is an adjunct faculty member for the Temple University Certificate of Financial Planning Program. He is a frequent speaker and facilitator on tax and financial planning topics. John has been quoted in the Wall Street Journal, MarketWatch.com, and USATODAY.com. He has written for the Journal of Financial Planning, and is a contributor to Retirement Weekly. John has also discussed financial and tax planning issues on various radio outlets.

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Non-Member Price $130

Member Price $100