Description

The Partnership & S Corporation Workshop is designed for experienced tax professionals who advise on pass-through entities. The program covers S corporation eligibility, shareholder basis, and the built-in gains tax, then works through partnership rules governing capital accounts, contributions, distributions, special allocations, and dispositions of partnership interests. The program concludes with a capstone review of a real LLC agreement.

Through an interactive approach that includes instructor-led discussion, group research, detailed computation exercises, and comprehensive case studies drawn from client fact patterns, participants will apply these concepts to practical tax scenarios and strengthen their ability to analyze complex pass-through entity issues.

Learning Objectives

Calculate shareholder stock and debt basis in an S corporation and apply the ordering rules governing basis adjustments.
Explain the S corporation built-in gains tax and identify the transactions and events that trigger it.
Compute Section 704(b) capital accounts and tax capital accounts, and distinguish each from a partner’s outside basis.
Apply the loss limitation rules under Sections 704(d), 465, and 469 to determine the deductible portion of a partner’s loss.
Evaluate the tax consequences of partner contributions, including nonrecognition treatment under Section 721 and the recharacterization rules of Section 724.
Calculate the tax consequences of current and liquidating partnership distributions involving cash, hot assets, and other property.
Analyze whether a special allocation satisfies the substantial economic effect requirements of the Section 704(b) regulations.
Compute the gain or loss on the sale or redemption of a partnership interest, including the related Section 743(b) and Section 734(b) adjustments.
Analyze an LLC agreement to identify the key tax provisions governing allocations, distributions, and capital account maintenance.