Course Details

Partnership Taxation: Allocations In Partnership And LLC Agreements

Webinar: ID# 1035745
Recorded On-Demand
About This Course:
Every partnership or LLC agreement between at least two members must address tax allocations. Experts have developed provisions that now commonly appear in such agreements to address tax allocations.

This webinar will provide an overview of those provisions. The material is designed for new tax attorneys who are trying to grasp the complexity of the tax provisions in the typical partnership or LLC agreement and the nontax attorneys and business owners who see those provisions and would like to better understand their purpose.

The content will work through examples and sample language to cover the concepts. Although the discussion will inevitably require using technical language and covering technical topics, the discussion is intended to be an overview that covers a broad swath of material.What You'll Learn:Overview of Partnership Allocations
  • General Tax Rules
  • Substantial Economic Effect
  • Partners' Interests in a Partnership
General Allocation Structures
  • Allocation Driven Structures
  • Basic Proportionate Sharing of Profits and Losses
  • Layer Cake Allocations
  • Distribution Driven Structures
  • Target Allocations
  • Allocations According to Partners' Interests in the Partnership
Basics of Allocation Language in Partnership and LLC Agreements
  • Definitions of Profits and Losses
  • Book Value
  • Special Allocations
  • Minimum Gain Chargeback
  • Qualified Income Offset
  • Regulatory Allocations
  • Section 704(c) Property
  • Allocation of 704(c) Items
Partnership Taxation: Allocations In Partnership And LLC Agreements
or via On-Demand
Course Details
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