The Internal Revenue Service considers Section 704(b)'s substantial economic effect regulations among the most complex. This course teaches the Treasury Regulations enable simple compliance through (Per Capita: Balances: Ratios) capital account accounting method truncated transitivity, economic effect equivalence, and substantiality's conclusive presumption. The partnership special allocations public policy mandate is made clear thereby: encourage going concern productivity while discouraging its abandonment.
This webcast involves Section 179 depreciation expense at the partnership level in a startup operation. Although not incorporated into this webcast, Dr. Jenkins wants to share his paper, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships or S Corporations." The paper is currently in peer review at a university tax journal. Also, the ACPEN/BPN webcast based on this paper will be first aired during the week of September 25-29, 2017. Please be sure to look for that announcement and register for the webcast.
Partnership Special Allocation Substantial Economic Effect: History, Background, and Policy
Capital Account Accounting
Economic Effect's Trinity
Simplified Substantiality Compliance: the Treas. Reg. Section 1.704-1(b)(2)(iii)(c)(2) Conclusive Presumption
Partnership Agreement Special Allocation Substantial Economic Effect Provisions
Crunching Some Numbers: Going Concern Capital Account Maintenance
Crunching Some Numbers: Liquidation Capital Account Maintenance