When a purchaser buys an existing partner’s partnership interest or the interest of a member of a limited liability corporation (LLC) taxed as a partnership, the amount paid becomes the basis for the purchaser’s partnership interest (outside basis). If the partnership’s assets have appreciated sufficiently, the difference between the new partner’s inside and outside basis can be substantial.
DESIGNED FOR
Any Accounting and Finance Professional who wishes to understand the tax rules and economic opportunities associated with having a partnership make a Section 754 election
BENEFITS
- Determine the amount of a Section 754 basis step-up
- Know how to allocate the basis step-up to the partnership's assets
- Know how a partnership makes a Section 754 election and reports it to the IRS
HIGHLIGHTS
- How and why a partnership makes a 754 election
- The effect of the 754 election when an interest in a partnership is sold or inherited
- How the 754 election applies when a partnership makes a distribution of property to one or more of its partners
- How to make the 754 basis adjustment
COURSE LEVEL
Intermediate
PREREQUISITES
A basic understanding of the tax rules impacting individuals and pass-through entities
ADVANCE PREPARATION
None
ADDITIONAL NOTES