92421 9.00

Partnership Taxation Concepts and Planning Strategies*

Author: James R. Hamill

CPE Credit:  9 hours for CPAs
9 hours Federal Tax Related for EAs and OTRPs
9 hours Federal Tax Law for CTEC

This extensive on-demand course with nationally recognized tax practitioner and instructor James Hamill, CPA, Ph.D. provides a practical review of how to deal with the most commonly encountered partnership tax issues from a planning and compliance perspective.

Debt allocations, distributions, bringing in new partners, sales of partnership shares, and terminations all present myriad tax questions that require careful consideration. Dr. Hamill will clarify and deepen your understanding of these critical issues. He excels at taking complex tax concepts and explaining them in a clear and easy-to-understand manner that you can apply in your practice with your partnership and partner clients. You don’t want to miss this helpful discussion on this essential topic!

All professionals involved with partnership tax compliance and planning matters will benefit from this insightful webinar.

*Denotes premium content.

This course is excluded from the following subscription programs:
Value Pass, Self-Study Package, Webinar Package, Self-Study & Webinar Package, and Firm Package.


Publication Date: May 2018

Designed For
CPAs, EAs, tax preparers and other tax professionals with responsibility for review of partnership and LLC tax returns and planning for partnership tax entities

Topics Covered

  • Applicability of self-employment tax to partnership income, including LLC members
  • The economic effect test for respecting partnership allocations
  • Allocations of partnership nonrecourse deductions
  • Section 704(c) allocations of built-in gains and losses
  • Determining partner's shares of recourse and nonrecourse debt
  • Sales and exchanges of partnership interests
  • Section 743 adjustments to basis for a purchasing partner
  • Tax treatment of distributions of money and property
  • Section 734 basis adjustments for partnership distributions
  • The impact of the Tax Cuts and Job Creation Act of 2017
  • Overview: Impact of Section 199A deduction
  • Overview: Centralized Audit Rules
  • Partner SE Tax Issues
  • Partners' Distributive Shares
  • Partners' Shares of Liabilities
  • Sales and Exchanges of Interests
  • Partnership Distributions
  • Partnership Terminations


Learning Objectives

  • Describe essential areas in partnership taxation
  • Identify tax planning opportunities and partnership pitfalls
  • Describe types of income subject to partner self-employment tax based on general rule
  • Identify LLC member self-employment tax
  • Recognize guaranteed payments
  • Identify exceptions to the general rule that the agreement controls, with respect to a partners' distributive shares
  • Differentiate statements regarding the substantial economic effect principles
  • Recognize the three requirements with respect to the economic effect safe harbor
  • Describe what Section 704(c) deals with
  • Identify methods for partnership allocation identified in the regulations prescribes that the cure must be an item of similar character
  • Describe the steps with respect to the qualified business income deduction
  • Recognize why debt shares matter
  • Identify statements with respect to the zero-value liquidation approach
  • Differentiate statements with respect to the considerations for nonrecourse debt shares
  • Recognize which type of elections a taxpayer should make in various scenarios
  • Describe gain recognition of partnership distributions
  • Differentiate correct statements regarding loss recognition of partnership distributions
  • Describe Section 734 adjustments
  • Identify safe harbor and disguised sale considerations
  • Recognize how many years of contribution should be closely evaluated as a potential disguised sale
  • Identify requirements for the separate self-employment tax exception related to retirement payments
  • Describe when an economic effect is substantial
  • Recognize when the economic effect safe harbors includes an alternate test for economic effect
  • Identify when the concept of minimum gain applies
  • Describe when pre-contribution gains and losses are not related to a partnership
  • Identify methods for partnership allocation
  • Recognize the approach a partnership distribution generally follows
  • Describe the result of losses from a partnership distributions



Instructional Method

NASBA Field of Study
Taxes (9 hours)

Program Prerequisites
Experience with Partnership Tax Returns

Advance Preparation


Additional Course Details

  • Filed of Study: Taxation
  • Publisher: Wolters Kluwer
  • Course Level: Intermediate
  • Pre-Requisites: None
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