This workshop will analyze selected language in publicly available partnership agreements dealing with important partnership tax issues. The discussion will examine the underlying tax reasons for the language, consider alternative approaches, and identify potential conflicts between partners that the wording may be designed to mitigate. Helpful tax provisions in partner buy-sell agreements, and redemption agreements, will also be evaluated.
Tax issues discussed will include agreement language addressing:
Methods of allocation pursuant to section 704(c)
Service partners and profits-only interests.
Section 754 election strategies.
Allocating income and losses per section 704(b).
Capital accounts and target allocations.
Method of accounting for variations during the tax year.
Retirement of a partner
New partnership audit rules.
Attendees will understand the significance of partnership agreement language addressing tax issues involving: formation, operation, distributions, and liquidations.
CPA, LL.M. (Taxation),
California State University, East Bay