JD Supra

[Webinar] IRC 754 Elections for Tax Counsel: Mastering Structuring Considerations of Basis Adjustments - Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 ...

This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and ...
Jurist

Streamlining the Section 754 Election Statement

Internal Revenue Service (IRS), Treasury. This document contains proposed amendments to the regulation relating to the requirements for making a valid election under section 754 of the Internal ...
Think Advisor

8938 / How is a sale of partnership interests taxed?

Editor’s Note: Under the 2017 tax reform legislation, the technical termination rule was repealed. Therefore, a partnership will be treated as though it is continuing even if more than 50 percent of ...
JD Supra

Now You See It – Now You Don’t. Like Magic, the City of Portland Disallows Depreciation Deductions Otherwise Allowable as a Result of Code Section 754

When a partner in a partnership sells his or her partnership interest to a new partner, this can create a mismatch between the partnership’s basis in its assets (inside basis) and the new partner’s ...
Think Advisor

Partnership Basis-Shifting Loopholes: IRS Final Regs

The IRS and Treasury have now finalized regulations that require partnerships to disclose information about certain transactions involving distributions and transfers of partnership interests and ...