Section 754 Step-Up in Basis: Understanding the Tax Issues for Partnerships and LLCs

Overview

You could pay $0 for this course!

This course qualifies for EA/IRS and CFP credit. If you need EA/IRS credit, please contact Tyler Dion (tdion@masscpas.org) after you have registered and provide him your PTIN number.

When a purchaser buys an existing partner's partnership interest or the interest of a member of a limited liability corporation (LLC) taxed as a partnership, the amount paid becomes the basis for the purchaser's partnership interest (outside basis). If the partnership's assets have appreciated sufficiently, the difference between the new partner's inside and outside basis can be substantial. This disparity can deprive the new partner of depreciation deductions and inflate his or her share of the gain from subsequent property dispositions unless a Section 754 election is in effect. The Section 754 election can also apply when a partnership makes a distribution of property and the basis of the distributed property to the partnership and the basis the partner/distributee will take in the distributed property are not equal. In this case, a partnership can recover basis it would otherwise lose if the 754 election were not in effect.

This course qualifies for reimbursement through the state’s Workforce Training Express Fund. Firms/companies with fewer than 50 staff can be reimbursed up to 100% of the cost of training and firms/companies with 50-100 employees can be reimbursed up to 50% of the cost of training. You must register for the course and apply for reimbursement through the Workforce Training Express Fund website a minimum of three weeks prior to the start of the course to be eligible. The course code for this program is C-6532. To learn more, click here or contact Julia Ekelund at jekelund@masscpas.org.

Highlights

How and why a partnership makes a 754 election The effect of the 754 election when an interest in a partnership is sold or inherited How the 754 election applies when a partnership makes a distribution of property to one or more of its partners How to make the 754 basis adjustment

Prerequisites

A basic understanding of the tax rules impacting individuals and pass-through entities

Designed For

Any Accounting and Finance Professional who wishes to understand the tax rules and economic opportunities associated with having a partnership make a Section 754 election

Objectives

Determine the amount of a Section 754 basis step-up Know how to allocate the basis step-up to the partnership’s assets Know how a partnership makes a Section 754 election and reports it to the IRS

Preparation

None

Fees

Credits

Level

Vendor

Fields of Study

Leader(s):

Michael Frost, Surgent McCoy CPE LLC

Leader Bios

Michael Frost, Surgent McCoy CPE LLC

Mike Frost, CPA, of Jacksonville, Alabama, provides tax consulting, continuing education, and motivational speaking services through his company, Mike Frost Enterprises. Mike is a former shareholder of MDA Professional Group, PC, where he managed the tax department of the Albertville office. Mike has 31 years of experience in public accounting, including but not limited to: Business and individual income tax preparation and planning; mergers and acquisitions; estate, gift, and trust tax preparation; small business consulting; Medicare planning and other elder care; audit representation; and religious groups and clergy. Mike has conducted CPE engagements and seminars throughout the United States and has served as technical advisor for tax articles in The Sand Mountain Reporter, a local newspaper. Mike has been a featured presenter at the Alabama Society of CPAs Annual Meeting and the Federal Tax Clinic held annually at the University of Alabama in Tuscaloosa. Mike graduated with “high honors and distinction” from Jacksonville State University with a major in accounting, a minor in finance, and a 4.0 GPA. He is a member of the American Institute of Certified Public Accountants and the Alabama Society of Certified Public Accountants. In addition, he is a graduate of the Tax Planning and Advising for Closely Held Businesses Certificate of Educational Achievement Program sponsored by the AICPA.

Return to Top