Partnerships and limited liability companies are among the most common business entity types in the United States. They are prized for their 'flow-through' tax benefits for both large and small businesses.

However, the tax rules governing the allocation of partnership income and loss are among the most technical, complex, and commonly misunderstood in the Internal Revenue Code, resulting in unintended tax consequences.

This presentation will help tax and business professionals better understand the rules governing partnership allocations and the commercial import of choices and elections that can be made within those rules.What You'll Learn:Capital Accounting

• Significance of Capital Accounts
  
• Substantial Economic Effect
  
• Partners' Interests in the Partnership

704(c) Considerations

• 704(c) Goals
  
• 704(c) Methodologies
  
• Reverse 704(c) Considerations

Partnership Agreement Allocation Approaches

• Safe Harbor Allocations
  
• Targeted Capital Accounts

Frequently Negotiated Issues

• Calculating Tax Distributions
  
• 704(c) Methodologies