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Section 754 Making the Election or Not - American...

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Section 754 Making the Election or Not - American...

Section 754 Making the Election or Not 2009 Fall Joint CLE Meeting American Bar Association Taxation Section Trust and Estate Law Division of

http://www.americanbar.org/content/dam/aba/events/real_property_trust_estate/joint_fall/2009/spratt_20090907145241093.authcheckdam.pdf

Date added: January 28, 2012 - Views: 158

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Internal Revenue Service Department of the...

2 making the election. Law and Analysis Under section 754, a partnership may elect to adjust the basis of partnership property where there is a distribution of ...

https://www.irs.gov/pub/irs-wd/0209046.pdf

Date added: November 2, 2015 - Views: 4

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Internal Revenue Service Department of the...

Internal Revenue Service Number: 200044009 Release Date: 11/3/2000 Index Number: 754.00-00 9100.00-00 Department of the Treasury Washington, DC 20224

https://www.irs.gov/pub/irs-wd/0044009.pdf

Date added: November 2, 2015 - Views: 3

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IRC 754: Partnership and Pass-Through Entity Basis...

Section 754 8 –Election to adjust basis of partnership property –If made, partnership must adjust basis pursuant to sections 734(b) and 743(b)

http://media.straffordpub.com/products/irc-754-partnership-and-pass-through-entity-basis-adjustments-2014-01-21/presentation.pdf

Date added: March 11, 2014 - Views: 13

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754 and Basis Adjustments for and LLC Interests

Presenting a live 110‐minute teleconference with interactive Q&A Section 754 and Basis Adjustments for Partnership and LLC Interests

http://media.straffordpub.com/products/section-754-and-basis-adjustments-for-partnership-and-llc-interests-2011-09-13/presentation.pdf

Date added: October 26, 2011 - Views: 93

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Disregarding 754 elections? A Harbinger of Things...

Disregarding 754 elections? A Harbinger of Things to Come. On Sept. 12, ... Section 754 (“754 election”) of the Internal Revenue Code of 1986 as amended (the

http://www.tscpa.com/Content/Files/tscpa/Journal/articles/Disregarding%20754%20Elections.pdf

Date added: October 4, 2012 - Views: 25

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§1.754–1 26 CFR Ch. I (4–1–10 Edition)

election under section 754 to apply the provisions of section 734(b) and 743(b). In addition, the following statement must be prominently displayed in cap-

http://www.gpo.gov/fdsys/pkg/CFR-2010-title26-vol8/pdf/CFR-2010-title26-vol8-sec1-754-1.pdf

Date added: September 9, 2014 - Views: 7

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NEW JERSEY DIVISION OF TAXATION

NEW JERSEY DIVISION OF TAXATION ... Pursuant to Internal Revenue Code section 754, ... federal adjustments such as an IRC §754 election are permitted for New Jersey

http://www.state.nj.us/treasury/taxation/pdf/pubs/tams/tam8.pdf

Date added: February 2, 2012 - Views: 17

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OPTIONAL BASIS ADJUSTMENTS - taxtaxtax.com

The Section 754 election applies to all distributions and transfers during the tax year with respect to which the election is initially filed, and to all such ...

http://taxtaxtax.com/pship/Optional%20BasisAdj.pdf

Date added: January 28, 2012 - Views: 39

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Tax Management Estates Gifts and Trusts Journal...

misuse, of the §754 election. A further trap was added by the American Jobs ... 2Unless otherwise specified, all section references are to the Internal Revenue Code

http://www2.gtlaw.com/pub/articles/2006/steinbergt06a.pdf

Date added: October 26, 2011 - Views: 43

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tax considerations in m&a transactions - Akin Gump

TAX CONSIDERATIONS IN M&A TRANSACTIONS BUSINESS LAW CURRENTS Page 1 of 5. ... 7 The reasons for not making the Section 754 election include the additional

http://cdn.akingump.com/images/content/5/2/v4/5297/Akin-Gump-Tax-Considerations-in-MA-Transactions.pdf

Date added: December 13, 2014 - Views: 11

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Internal Revenue Service Department of the...

Internal Revenue Service Department of the Treasury Washington, DC 20224 ... without making a section 754 election, having relied on its accountant who failed to

http://www.unclefed.com/ForTaxProfs/irs-wd/2004/0445006.pdf

Date added: March 16, 2013 - Views: 19

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INCOME TAX CONSIDERATIONS - | Briggs and Veselka

2. Effect of a Section 754 Election ..... 34 C. Distributions Within Seven Years of Contribution ...

http://www.bvccpa.com/wp-content/uploads/2011/02/Income_Tax_Problems_When_the_Estate_or_Trust_is_a_Partner.pdf

Date added: February 23, 2012 - Views: 20

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Cost Segregation FAQs - cpareport.com

Cost Segregation FAQ's ... admission of a new partner, the partnership can do a section 754 election to step up the basis to fair market value ,i.e., ...

http://www.cpareport.com/Webinars/Ernst/FAQ.pdf

Date added: October 9, 2012 - Views: 19

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Partnership Income Tax Problems When the Estate or...

Effect of a Section 754 Election ..... 35 C. Distributions Within Seven Years of Contribution ... INCOME TAX PROBLEMS WHEN THE ESTATE OR TRUST IS A PARTNER

http://www.cctaxlaw.com/sites/default/files/Partnership%20Income_Tax_Problems_When_the_Estate_or_Trust_is_a_Partner%20%283%29.pdf

Date added: August 8, 2013 - Views: 19

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Termination of a Partnership - University of...

2 Section 754 Election zMade on either – – Final Return of Old Partnership – Initial Return of New Partnership Basis Adjustment – Sec. 743(b)

http://www-bcf.usc.edu/~scharlac/assignments/Lecture%205.pdf

Date added: October 4, 2012 - Views: 23

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Partnership Basis Adjustments

Partnership Basis Adjustments Under Internal Revenue Code Section 754 Risë Flenner, CPA/PFS, JD Tax Partner November , 2014

http://tcvscpa.com/flyers/Session_6_-_754_Elections.pdf

Date added: December 17, 2014 - Views: 9

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Structuring a Buyout — Sale versus Redemption

Governing Code Section(s) §741, §751 §736, ... 15 A valid §754 election must be in place. ... SALE VERSUS REDEMPTION (cont’d)

https://doubletaxation.files.wordpress.com/2012/04/structuring-a-buyout-sale-versus-redemption.pdf

Date added: February 12, 2015 - Views: 12

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Internal Revenue Service, Treasury §1.754–1

election under section 754 to apply the provisions of section 734(b) and 743(b). In addition, the following statement must be prominently displayed in cap-

http://www.gpo.gov/fdsys/pkg/CFR-2008-title26-vol8/pdf/CFR-2008-title26-vol8-sec1-754-1.pdf

Date added: May 31, 2013 - Views: 29

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Taxation of Partnerships and LLCs Complex Tax...

Taxation of Partnerships and LLCs Complex Tax Issues CPE – 8 Credit Hours ... 2. Section 754 Election / Basis Adjustments under Sections 743 and 734 3.

http://barrancataxlaw.com/PDF/Partnership-8b.pdf

Date added: October 24, 2013 - Views: 15

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2011 LIMITED LIABILTY COMPANY (LLC) & PARTNERSHIP...

2011 LIMITED LIABILTY COMPANY (LLC) & PARTNERSHIP FEDERAL TAX UPDATE Gregory L. Gandy, CPA ... –Failure to make or document IRC Section 754 election CPA EXPORSURE .

http://www.biggskofford.com/wp-content/uploads/2011/12/greggandytaxupdate2011.pdf

Date added: June 13, 2013 - Views: 14

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Sub K Tax Issues Technical - Deloitte US

Sub K Tax Issues – Technical Terminations, “Regulatory” Allocations, §704(c) Property, ... Section 754Election to adjust basis of partnership property

http://www2.deloitte.com/content/dam/Deloitte/us/Documents/energy-resources/us-er-2014-aes-presentation-es8-topic1-112614.pdf

Date added: March 20, 2015 - Views: 1

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Optional Adjustments to Basis of Partnership...

The Section 754 Election We have just seen that there is great flexibility in the area of special ... of partnership property on transfer of a partnership interest, ...

http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1508&context=tax

Date added: July 21, 2013 - Views: 9

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POST 2012 FLP UPDATE - Cantrell & Cantrell, PLLC

THE SECTION 754 ELECTION ... his share of the underlying partnership assets when the partnership makes a § 754 election.91 The goal of § 754 is to achieve ...

http://www.cctaxlaw.com/sites/default/files/POST%202012%20FLP%20UPDATE.pdf

Date added: October 23, 2013 - Views: 6

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Advanced Form 1041 and Fiduciary Accounting

Advanced Form 1041 and Fiduciary Accounting By ... Section 754 Election Unless the estate elects out of the estate tax, the basis of a partnership interest is

http://www.bvccpa.com/wp-content/uploads/2011/02/Advanced_Form_1041_and_Fiduciary_Accounting.pdf

Date added: November 25, 2011 - Views: 19

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EXP ¶1684.025 Additional first-year depreciation...

Section 754 election. In general, ... additional first-year depreciation for the class of property that includes the qualified rehabilitation expenditures.

http://static.store.tax.thomsonreuters.com/static/samplePages/Sample_Checkpoint_USTR.pdf

Date added: November 20, 2013 - Views: 11

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BASIS ADJUSTMENTS RELATING TO TRANSFER OF...

BASIS ADJUSTMENTS RELATING TO TRANSFER OF PARTNERSHIP INTERESTS/DISTRIBUTIONS I. Section 754. ... The partnership has made an election under section 754,

http://www.sacbar.org/assets/no-2-f-basis-adjustments-relating-to-transfer-of-partnership-interests-distribu....pdf

Date added: May 29, 2015 - Views: 3

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TENNESSEE DEPARTMENT OF REVENUE WARNING SUBJECT...

earnings or loss, where the limited liability company has in effect an election under Section 754 of the Internal Revenue Code of 1986, as amended. SCOPE

https://www.tn.gov/assets/entities/revenue/attachments/11-45fe.pdf

Date added: January 17, 2016 - Views: 1

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State Tax E-News - Devine-Millimet

State Tax E-News E-MAIL ALERTS State & Local Tax Practice STATE TAX UPDATE ... IRC section 754 or section 338 election must be included in the income of

http://devinemillimet.com/uploads/docs/E-Tax_Newsletter-082007.pdf

Date added: April 27, 2012 - Views: 16

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Resolving IRS issues before they become IRS...

partnership unless a check the box election is made ... Partnership transfers under section 754 Six-month extension–elections that should be filed with

http://rsmus.com/pdf/wc_tax_controversy_10092013.pdf

Date added: November 28, 2015 - Views: 2

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Reg. Section 301.9100-2(d) - Bradford Tax...

organization under section 508; (v) The election to be treated as a ... and distributions under section 754; (vii) The estate tax election to specially ...

http://www.bradfordtaxinstitute.com/Endnotes/Reg_301_9100-2d.pdf

Date added: September 24, 2013 - Views: 12

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Optional Basis Adjustments Solutions -...

Optional Basis Adjustments Solutions ... Section 743(b)(1) ... A §754 election applies to all distributions and transfers during the taxable year “with

http://taxtaxtax.com/pship/cases/Case9Sol.pdf

Date added: November 10, 2011 - Views: 28

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ProSystem fx Tax – Partnership

ProSystem fx Tax simplifies your allocation work, by providing you with the ability to allocate: ... Excess basis adjustments under IRC Section 754 from

http://tax.cchgroup.com/pdfs/Partnership.pdf

Date added: December 6, 2012 - Views: 1

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Proposed regulations - Partnership guidance...

section 754 election for the taxable year of the transfer (solely with respect to the interest transferred). Comments are requested on the scope of this ruleand the

http://www.kpmg.com/US/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Documents/14023.pdf

Date added: May 8, 2014 - Views: 11

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Planning for the Termination of an Interest in a...

OF AN INTEREST IN A PARTNERSHIP -WITHDRAWALS, DISTRIBUTIONS AND OTHER EXIT STRATEGIES ... This same result occurs if the section 754 election is made for the.

http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1305&context=tax

Date added: December 23, 2012 - Views: 23

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Testimony Before the Subcommittee on Select...

Prior to 2004, in some cases, the failure to make a section 754 election could have resulted in the duplication of a loss recognized by a distributee partner or a ...

http://www.mwe.com/files/Uploads/Documents/Pubs/Rubin_SRM_Statement.pdf

Date added: October 26, 2013 - Views: 7

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Let’s explore a straightforward example. In...

However, another option is for the partnership to trigger the Section 754 election to equalize the partner’s outside and inside basis. Revaluations permit gains or

http://dusmanlaw.com/wp-content/uploads/2009/04/revaluation_of_partnership_capital_accounts.pdf

Date added: November 10, 2011 - Views: 39

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Distributions Without Section 751 - mntaxclass.com

Distributions Without Section 751 • Current Distributions ... With Section 754 Election If Blackacre is sold for $1,000K, then zero recognized gain due to

http://www.mntaxclass.com/files/205_Ch_15_Distribs_Part_1.pdf

Date added: February 9, 2016 - Views: 1

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AMERICAN JOBS CREATION ACT OF TAX ACT EFFECTS ON...

On October 22, 2004, President Bush signed into law H.R. 4520, the American Jobs Creation Act of 2004 ... had made a section 754 election, ...

http://www.kslaw.com/library/pdf/memo4.pdf

Date added: May 11, 2013 - Views: 10

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FAUST FTC Panel Slides (2) - American Bar...

Is a Section 338(g) Election Still ... – Any acquisition of an interest in a partnership which has a section 754 election in effect ... FAUST FTC Panel ...

http://www.americanbar.org/content/dam/aba/events/taxation/taxiq-fall11-faust-ftc-slides.pdf

Date added: July 30, 2015 - Views: 5

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Death of a Partner 17-2 - mntaxclass.com

Section 754 Election to Continuing Partners on Death of a Partner and Buy-out of Successor 4. Example (5) (not in text) The ABC Partnership is

http://mntaxclass.com/files/210_Ch_17_Death_of_Ptr.pdf

Date added: January 17, 2016 - Views: 1

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Sales vs. Redemptions of Partnership Interests

Sales vs. Redemptions of Partnership Interests ... LLC makes a Code Sec. 754 election or has one in ... Section 751 of the Code was enacted to prevent the conversion ...

http://www.lgclaw.com/Publications/Levun-Cohen.pdf

Date added: December 22, 2011 - Views: 38

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Consequences of Liquidating Distribution

Consequences of Liquidating Distribution ... No Sec. 754 Election in Effect ... Section 755 zAllocation between Sec. 1221/1231

http://www-bcf.usc.edu/~scharlac/assignments/Lecture%206.pdf

Date added: December 6, 2012 - Views: 5

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Key Tax Considerations for Private Equity...

A Section 754 election allows the partnership to adjust the basis of its ... A private equity fund acquiring a direct or indirect interest in

http://www.mwe.com/files/Uploads/Documents/Pubs/Focus_on_Private_Equity_June_2012.pdf

Date added: October 4, 2012 - Views: 4

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Acquisition Planning Strategies - San Jose State...

• Acquisition of corporation with §338 election • Acquisition of DRE that is treated as stock purchase under local law ... Section 754 Election

http://www.cob.sjsu.edu/acct&fin/tax-institute/SpeakerMaterials2011/AcquisitionPlanning.pdf

Date added: October 4, 2012 - Views: 2

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Partnership Inequalities: The Consequences of...

Partnership Inequalities: The Consequences of Book/Tax Disparities ... The partnership makes an election under section 754 for the year of the distribution, ...

http://www.law.uchicago.edu/files/file/abrams.pdf

Date added: April 30, 2014 - Views: 10

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Notice 2014-44 provides guidance regarding events...

Notice 2014-44 provides guidance regarding events that are dispositions under Section 901(m) ... interests for which a Section 754 election is in effect, and,

http://www.pwc.com/us/en/tax-services/publications/insights/assets/pwc-notice-2014-44-provides-901m-guidance.pdf

Date added: November 28, 2015 - Views: 2

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M&A AGREEMENTS: TRAPS, TRENDS AND TIPS

M&A AGREEMENTS: TRAPS, TRENDS AND TIPS ALI CLE . Corporate Taxation . April 5, 2013 . R. David Wheat Thompson & Knight LLP Dallas, Texas ... •Section 754 Election

http://www.tklaw.com/files/Publication/a07fb8de-02ea-4dc6-a549-dbd71a6f462a/Presentation/PublicationAttachment/69b00cb9-60f6-4c82-b676-de5700a9c29d/M%26A%20Agreements%20Traps,%20Trends,%20and%20Tips.pdf

Date added: March 16, 2014 - Views: 22

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Mergers & Acquisition of Pass-through Entities: S...

Mergers & Acquisition of Pass-through Entities: S Corporations, Partnerships & LLCs ... section 754 election can provide buyer with a fair market value in the basis ...

http://www.pillsburylaw.com/siteFiles/Events/MergersAcquisitionofPassthroughEntities.pdf

Date added: February 2, 2012 - Views: 33