Reporting Partnership Targeted Tax Allocations (Completed)

Partnerships allow partners to reach an agreement with respect to the allocation of items of income, gain, deduction, and loss — provided the agreement has substantial economic effect. Regulations finalized in 1985, at the height of the tax shelter days, provide several “safe harbors” to the structure of allocations that comply with the economic effect test. These regulations require that the partnership liquidate based on capital accounts and have largely driven the form of most partnership agreements.

After the passive loss rules eliminated the classic tax shelter arrangement, many advisors looked for alternative structures that focused on how partners would distribute money and property, and then use the distribution arrangement to determine allocations of partnership items. These arrangements are often called “targeted” allocations as they use allocations to hit a target capital account. The agreement itself does not prescribe a particular allocation scheme, but instead forces the tax return preparer to make allocations that tie capital to the agreed-to distribution scheme.

Join nationally recognized tax practitioner, instructor and commentator James Hamill, CPA, Ph.D., for this two-hour CPE webinar that provides a practical review of how to make partnership allocations based on a targeted allocation agreement. This program makes liberal use of specific examples to illustrate the “how to” of targeted allocations.

Who Should Attend
CPAs, EAs, tax preparers and other tax professionals with responsibility for partnership tax return compliance.

Topics Covered

• An overview of the traditional safe harbor allocation scheme
• How targeted allocations differ from traditional safe harbor allocations
• Why targeted allocations shift risk from the drafter of the agreement to the preparer of the return
• Illustrations of "how to" make targeted allocations with (12) specific examples
• Illustrations of how Section 704(c) interacts with targeted allocations
• Illustrations of how nonrecourse deductions interact with targeted allocations
• The use of bottom line or item allocations to make targeted allocations
• Possible guaranteed payments or capital shifts resulting from targeted allocations
• The need to review a targeted allocation agreement before it is signed to avoid compliance nightmares

Learning Objectives

• Recognize and apply essential aspects partnership targeted allocations
• Identify how to properly make partnership allocations based on a targeted allocation agreement
• Recognize how to help clients understand how targeted allocations will affect their tax returns

Level
Intermediate

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Experience with partnership tax returns.

Advance Preparation
None