transcript   Transcript

Section 704(c): Operations and Implications for Negotiating a Deal and Drafting a Partnership Agreement

Recorded on: Jun. 7, 2018
Running Time: 01:30:30

Full Transcript:

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Taken from the Web Program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018  Recorded June, 2018 in San Francisco [01:30:30]

Book/tax disparities and how the partnership tax rules, before and after the Tax Cuts and Jobs Act, deal with these differences through the mechanics of Section 704(c) and reverse Section 704(c) allocations: the traditional method, ceiling limitation principles, traditional method with curative allocations, remedial allocation method, various operating rules in the Section 704(c) regulations, Section 704(c)(1)(C); anti-abuse provisions, tax distribution considerations, and planning concepts
Ari Berk, Afshin Beyzaee
The purchase price of this Web Program segment includes the following article from the Course Handbook available online:

  • Making Section 704(c) Sing for You
    Blake D. Rubin, Andrea Macintosh Whiteway
  • Implications of Section 704(c) for Negotiating a Partnership Agreement (Chicago) (PowerPoint slides)
    Andrea Macintosh Whiteway, Beverly M. Katz
  • Implications of Section 704(c) for Negotiating a Partnership Agreement (New York) (PowerPoint slides)
    Andrew W. Needham, Dina A. Wiesen
Presentation Material
  • Implications of Section 704(c) for Negotiating a Partnership Agreement
    Ari Berk, Afshin Beyzaee
    • (s)
      Ari Berk ~ Deloitte Tax LLP
      Afshin Beyzaee ~ DLA Piper LLP
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