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Simple Substantial Economic Effect Regulatory Compliance:an Overview

 
 Friday, Nov. 30, 2018 from 2:00 pm to 4:42 pm
 Online
 
3.0
19 / 2-31525
Registration is Open
VSCPA Members
$99.00 Regular Registration
Nonmembers
$129.00 Regular Registration
Designed For:
*Recognize whether a transaction is correctly designed as consistent with Congress’s partnership special allocations productivity policies *Recognize when a partnership agreement’s provisions correctly rebut the presumptive Per Capita method for purposes of determining a partner’s interest in the
Prerequisite:

Participants in this lecture should have some basic understanding of: Partnership capital account accounting, Partnership capital account account methods, and Partnership tax law.

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.

Syllabus

Lesson 1.

Partnership Special Allocation Substantial Economic Effect: History, Background, and Policy

Lesson 2.

Capital Account Accounting

Lesson 3.

Economic Effect's Trinity

Lesson 4.

Simplified Substantiality Compliance: the Treas. Reg. Section 1.704-1(b)(2)(iii)(c)(2) Conclusive Presumption

Lesson 5.

Partnership Agreement Special Allocation Substantial Economic Effect Provisions

Lesson 6.

Crunching Some Numbers: Going Concern Capital Account Maintenance

Lesson 7.

Crunching Some Numbers: Liquidation Capital Account Maintenance

Related Events

Objectives

*Recognize whether a transaction is correctly designed as consistent with Congress’s partnership special allocations productivity policies  

*Recognize when a partnership agreement’s provisions correctly rebut the presumptive Per Capita method for purposes of determining a partner’s interest in the partnership   

*Recognize the necessary partnership agreement provisions that correctly achieve (Per Capita: Balances: Ratios) capital account accounting method truncated transitivity  

*Recognize the necessary partnership agreement provisions that correctly provide economic effect trinity’s elements  

*Recognize the partnership agreement liquidation adjustment provisions necessary to correctly achieve economic effect equivalence

*Recognize substantiality’s conclusive presumption requires the partnership agreement correctly provide offsetting allocations that, in large part, occur more than five years after the originating allocation  

*Recognize when a substantial economic effect financial forecast correctly shows there is a reasonable possibility the special allocation will affect substantially the dollar amounts to be received by the partners of the partnership, independent of tax consequences

Speakers

Advanced Preparation

Purchase and read journal article relating to course, and Review the Course Materials.

Vendor

The Virginia Society of CPAs (VSCPA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBARegistry.org.

For more information regarding refund, complaint, program cancellation or other policies, visit our Registration Policies page or call (800) 733-8272.