PARTNERSHIP ISSUES

This webinar will provide a concise but sophisticated overview of partnership income taxation and select other partnership tax issues, focusing on how best to advise businesses operating through an LLC in structuring its operations.

The program will start with a detailed analysis of the benefits and drawbacks operating a business through an LCC taxable as a partnership compared to an S Corp or C Corp.  The program will then delve into the common everyday issues that arise, starting with formation of the entity, issuance of equity to owners (including profits interests issued for services), common tax issues arising from operations, and finally the tax issues related to the exit from the LLC, including structuring redemptions under Code Section 736 and the optimal way to structure the sale of the business (including whether to sell the LLC interests or the underlying assets).

Specific issues to be addressed:

1. Self-employment tax issues: what you can and cannot do
2. Capital accounts: book vs. tax issues
3. Determining basis: key issues and technical analysis for calculating basis
4. Dealing with debt: recourse, nonrecourse, and why it matters
5. Guaranteed payments, distributive shares, and draws: understanding the difference
6. Section 754
   1. What triggers the tax rule
   2. How to track and report the change to assets affected

Registration Form: 2025 Spring CPE Registration Form