How debt is allocated to the partners in a partnership is important. It dictates how much money may be taken tax-free as a distribution, the losses that flow down to the partners, and the gain or loss on the sale of a partnership interest.
DESIGNED FOR
Tax practitioners who are looking to improve their knowledge of debt allocations and how they affect a partner’s tax basis
BENEFITS
- State how debt allocations affect the calculation of a partner’s basis in the partnership
- Recognize how recourse and nonrecourse debt are allocated to partners
- Identify the tax effects of 704(c) on contributed property
HIGHLIGHTS
- Recourse debt allocations
- Constructive liquidation scenarios
- Nonrecourse debt allocations
- Minimum gains and nonrecourse deductions
- Section 704(c) gains
- Allocations under 704(c)
PREREQUISITES
Working knowledge of fundamental partnership tax concepts
ADVANCE PREPARATION
None
ADDITIONAL NOTES