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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: 4

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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: 5

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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: 160

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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: 97

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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: 41

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Sect. 743(b) Basis Adjustments on Partnership...

Sect. 743(b) Basis Adjustments on Partnership Interests ... If the ppp ,artnership has a Sect. 754 election in effect, then the partnership must adjust the basis of

http://media.straffordpub.com/products/sect-743-b-basis-adjustments-on-partnership-interests-2011-12-14/presentation.pdf

Date added: December 19, 2012 - Views: 9

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NEW JERSEY DIVISION OF TAXATION - State of New...

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: 20

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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: 14

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IRC Section 754 Election (September 2011) - State...

TENNESSEE DEPARTMENT OF REVENUE REVENUE RULING # 11-45 WARNING Revenue rulings are not binding on the Department. This presentation of the ruling in a

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

Date added: January 17, 2016 - Views: 2

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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: 30

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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: 45

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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: 4

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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: 11

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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: 18

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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: 27

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Internal Revenue Service, Treasury §1.743–1

nership makes a section 754 election. The lower tier’s basis in the contrib-uted assets and the upper tier’s basis in the partnership interest received in the

http://www.gpo.gov/fdsys/pkg/CFR-2010-title26-vol8/pdf/CFR-2010-title26-vol8-sec1-743-1.pdf

Date added: May 31, 2013 - Views: 4

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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: 14

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A PROFESSIONAL DEVELOPMENT JOURNAL for the...

A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES ... A Section 754 election allows the entity to adjust the basis of partnership assets

http://cendsel.com/PDFs/2010-Jan-Feb-Alfonsi.pdf

Date added: August 10, 2014 - Views: 20

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

Date added: May 1, 2012 - Views: 5

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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/imageserver/KSPublic/library/pdf/memo4.pdf

Date added: July 9, 2013 - Views: 1

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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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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: 22

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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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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: 14

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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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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: 20

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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: 2

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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: 20

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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: 35

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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: 11

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POST 2012 FLP UPDATE - cctaxlaw.com

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: 8

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Notice 201444 - Foreign tax credits and section...

Notice 201444 - Foreign tax credits and section 901(m) covered asset acquisitions ... interest in a partnership for which a section 754 election is in effect; ...

http://www.kpmg.com/US/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Documents/14407-jul21-2014.pdf

Date added: April 20, 2015 - Views: 2

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Partnership Terminations – What Changes, What...

Partnership Terminations – What Changes, What Doesn’t, ... Section 708(b)(1)(A) ... but a §754 election would neutralize the impact of the §704(c) ...

http://www.grantthornton.com/staticfiles/GTCom/Tax/Corp-SFTS%20files/Partnership%20terminations%20BNA%20TMREJ.pdf

Date added: February 17, 2012 - Views: 29

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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: 44

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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: 40

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Section 754 Survey 1.10.05 - altassets.net

Survey of IRS Section 754 Best Practices for General Partners ... partnership election in connection with the recently enacted tax legislation referred to as the Section

https://www.altassets.net/pdfs/nyppe_section754a.pdf

Date added: August 10, 2014 - Views: 1

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State Tax E-News - Devine Millimet Attorneys at...

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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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: 13

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MERGERS AND CONVERSION - Greenberg Traurig

MERGERS AND CONVERSIONS; PASS-THROUGH AND DISREGARDED ENTITIES; PRIMARY TAX PLANNING ISSUES Gregory M. Marks ... make a Section 754 election for their benefit. b.

http://www2.gtlaw.com/pub/articles/2002/marksg02a.pdf

Date added: December 26, 2012 - Views: 3

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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: 26

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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: 4

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IRS issues foreign tax credit guidance under ...

Section 754 election, an RFA that is subject to multiple Section 743(b) CAAs (a Prior Section 743(b) CAA and a Subsequent Section 743(b)

http://www.ey.com/Publication/vwLUAssets/US_IRS_issues_foreign_tax_credit_guidance_under_Section_901(m)/$File/2014US_CM4610_US%20IRS%20issues%20FTC%20guidance%20under%20Section%20901(m).pdf

Date added: April 20, 2015 - Views: 1

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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: 29

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LATE ELECTIONS AND SECTION 9100 - TexasBarCLE

Late Elections and Section 9100 Chapter 4 3 (Author’s Comment: Notice that relief for statutory elections is only allowed an automatic 6-month extension?

http://www.texasbarcle.com/Materials/Events/6943/14878_01.pdf

Date added: December 10, 2013 - Views: 11

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Alternative Financial Reporting Option for Real...

Alternative Financial Reporting Option ... A partnership can elect under Internal Revenue Code Section 754 to adjust the ... election applies to all transfers that ...

http://www.dhgllp.com/res_pubs/GAAP-vs-Tax-Basis-Financial-Statements.pdf

Date added: June 22, 2013 - Views: 24

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Section 754 Trap for the Unwary-Tax Planning Tool-...

1 Section 754: Trap for the Unwary, Tax Planning Tool, or Both? by Philip F. Postlewaite Harry R. Horrow Professor of Law and Director of the Tax Program

http://chattanoogataxpractitioners.org/images/PDFs/2013-05-Philip_Postlewaite-Section_754_Trap_for_the_Unwary_Tax_Planning_Tool_or_Both.pdf

Date added: March 20, 2015 - Views: 3

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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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Example - ALI CLE

A Section 754 Paradox: ... Given that a sectio n 754 election would typically be made by the ... The following example illustrates the trap.

http://files.ali-aba.org/thumbs/datastorage/skoobesruoc/pdf/CL033-CH08_thumb.pdf

Date added: February 23, 2012 - Views: 52

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M T C P T – Technical Series CATALOG

2. Section 754 Election and Basis Adjustments 3. Contribution of Property 4. Contribution of Services 5. Distributions: Cash, Property, and Debt

http://barrancataxlaw.com/PDF/technical.pdf

Date added: November 19, 2013 - Views: 6