PS: Partnership Distributions (456)

General Description:

The Partnership Series is taught on a basic level for new tax professionals. The participant will review the taxation of distributions of cash, property, marketable stock, and securities to partners in a partnership.

Learning Objectives:

After completing this course the participant will be able to:

• Summarize the rules that apply to current and liquidating distributions, including the amount of the basis adjustment if a §754 election is in effect.
• Discuss disproportionate distributions under §751(b), including accounting for a partner's interest in unrealized receivables and substantially appreciated inventory.
• Determine the tax effect of distributions to retiring and deceased partners, including payments for unstated goodwill, the different options available for reporting gains and losses, and the effect of a §754 election.
• Discuss the disguised sale rules as applied to distributions.
• Apply the 3.8% Medicare tax to partnership distributions.
• Determine the tax effect of distributions of marketable stock and securities as well as the treatment of virtual currencies.
• Report distributions on Form 1065.
• Identify income in respect of a decedent (IRD), the types of IRD items, and the effect of a §754 election.
• Explain the self-employment tax problems that result from distributions.
• Distinguish and describe the tax effects of cross-purchase agreements and redemption agreements, with and without a §754 election.

Instructors:

Mark A. Vogel is a retired professor and director of the University of Denver Graduate Tax Program, where for 38 years he taught courses in individual, fiduciary, tax accounting, partnership, and corporate taxation. He is the author of Divorce Taxation Guide (John Wiley & Sons) and Individual Taxation (Shepards/McGraw-Hill). He received a J.D. and LL.M. in Taxation from the University of Denver College of Law and an undergraduate accounting degree from the University of Notre Dame. He is also a CPA licensed in Illinois.

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