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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: 145

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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: 6

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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 ...

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

Date added: October 26, 2011 - Views: 40

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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: 80

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Internal Revenue Service Department of the...

Section 754 provides ... Section 1.754-1(b) of the Income Tax Regulations provides that an election under § 754 and this section to adjust the basis of partnership ...

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

Date added: January 29, 2012 - Views: 19

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Disregarding 754 elections? A Harbinger of Things...

754 elections? A Harbinger of Things to Come. On Sept. 12, 2011, the Tennessee ... by ignoring the 754 election and the Section 743(b) adjustment (“743(b)

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

Date added: October 4, 2012 - Views: 9

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Tax Management Estates Gifts and Trusts Journal...

Section 754 addresses this "basis mismatch" by allowing the partnership to elect to make ... §754 election for the year of death ...

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

Date added: October 26, 2011 - Views: 28

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NEW JERSEY DIVISION OF TAXATION

Pursuant to Internal Revenue Code section 754, ... federal adjustments such as an IRC §754 election are ... by the IRC §754 adjustment and report the net amount ...

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

Date added: February 2, 2012 - Views: 5

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OPTIONAL BASIS ADJUSTMENTS

basis adjustment made for the benefit of the incoming partner is carried over to the new partnership. However, if the partnership does not have a Section 754 election ...

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

Date added: January 28, 2012 - Views: 31

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Internal Revenue Service, Treasury §1.743–1

619 Internal Revenue Service, Treasury §1.743–1 the basis adjustment into account under section 732. (ii) Reallocation of basis. A transferee

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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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: 9

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Newsletter WriteUps for Website

January 2010 Ask The Experts – IRC Section 754 Election One of the most frequent questions we receive from accountants is, 'How do I properly depreciate

http://costsegregationinformation.com/resources/1/Newsletter%20-%20January%202010.pdf

Date added: November 19, 2013 - Views: 8

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

– Any acquisition of an interest in a partnership which has a section 754 election in effect – ... § 338 Election (§ 901(m)) No § 338 Election Year 1 E&P ...

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

Date added: April 6, 2014 - Views: 1

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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: 11

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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: 16

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Internal Revenue Service Department of the...

Regulations, that X be granted an extension of time to make an election section 754 of ... extension of time for making the section 754 election until sixty ...

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

Date added: March 16, 2013 - Views: 7

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Cost Segregation FAQs

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: 3

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Partnership Income Tax Problems When the Estate or...

THE SECTION 754 ELECTION ... his share of the underlying partnership assets when the partnership makes a § 754 election.88 The goal of § 754 is to achieve ...

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: 5

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tax considerations in m&a transactions - Akin Gump...

the transaction to be respected as a non-recognition transaction. ... Once made, the Section 754 election will apply to all partnership

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

Date added: December 13, 2014 - Views: 1

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Sales vs. Redemptions of Partnership Interests

purposes of this section, if a partnership transfers money, ... partnership, and, if a Code Sec. 754 election is made or is in effect, the partnership will amortize

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

Date added: December 22, 2011 - Views: 25

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Internal Revenue Service Department of the...

3 PLR-144301-01 deduction allowed or allowable in any prior year had the section 754 election been timely made. Except as specially set forth above, we express no ...

http://www.unclefed.com/ForTaxProfs/irs-wd/2002/0234057.pdf

Date added: October 4, 2012 - Views: 12

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Sale of a Partnership Interests

where a Code Sec. 754 election is made, ... partnership interest which is in excess of, ... under that Code section if Code Sec. 1250 applied to all depreciation ...

http://taxtaxtax.com/pship/Sale%20of%20a%20Partnership%20Interests.pdf

Date added: January 17, 2012 - Views: 17

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Testimony Before the Subcommittee on Select...

partnership interests regardless of whether the partnership makes an election under section 754 to adjust the basis of its property under these provisions.

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

Date added: October 26, 2013 - Views: 1

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ARTNERSHIP USINESS OMBINATIONS UCCESSOR LIABILITY...

including money.135 If the partnership has a Section 754 election in effect, or makes an election for the year of the distribution, ...

http://images.jw.com/com/publications/122.pdf

Date added: September 22, 2012 - Views: 2

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State Tax E-News - Devine Millimet

IRC section 754 or section 338 election must be included in the income of the seller™s final return when calculating state business taxes. Third, the

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

Date added: April 27, 2012 - Views: 6

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Advanced Form 1041 and Fiduciary Accounting

1041 rather than the Form 706, it must attach an election to Form 1041 that ... Section 754 Election Unless the estate elects out of the estate tax, ...

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

Date added: November 25, 2011 - Views: 7

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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: 2

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EXP ¶1684.025 Additional first-year depreciation...

depreciation of $100,000 (20% of $500,000); ... Section 754 election. In general, any increase in the basis of qualified property due to a section 754 election ...

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

Date added: November 20, 2013 - Views: 1

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A PROFESSIONAL DEVELOPMENT JOURNAL for the...

Section 754 elections, and their resultant ad- ... Finally, the non-availability of a Section 754 election to S corporations suggests that a discount

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

Date added: August 10, 2014 - Views: 1

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Stay Current Recent Rulings Favor Taxpayers'...

Recent Rulings Favor Taxpayers’ Statute of Limitations Defense ... (by means of a technical termination and Section 754 election, as in Bakersfield).

http://www.paulhastings.com/assets/publications/1399.pdf

Date added: May 13, 2012 - Views: 5

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THE SECTION 734(b) BASIS ADJUSTMENT NEEDS REPAIR

THE SECTION 734(b) BASIS ADJUSTMENT NEEDS REPAIR Howard E. Abrams* I. INTRODUCTION ... When an election under section 754 is made, the electing partnership becomes

http://www.jstor.org/stable/20772471

Date added: August 12, 2013 - Views: 1

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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: 1

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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: 2

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Capturing Capital Gain While Staying in the Deal...

do not have a Section 754 election in effect are required to reduce the inside basis of partnership property under Section 734(b) ... Capital Gains, Real Estate

http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1156&context=tax

Date added: April 30, 2013 - Views: 2

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Example - ALI CLE

A Section 754 Paradox: Basis Step-Up Trigg ers Gain Recognition ... devastating consequences. Given that a sectio n 754 election would typically be made by the

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

Date added: February 23, 2012 - Views: 27

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Proposed regulations - Partnership guidance...

has the same section 704(c)(1)(C) basis adjustment as the section 704(c)(1)(C) ... 743 unless the partnership made an election under section 754. The 2004 JOBS

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

Date added: May 8, 2014 - Views: 1

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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: 5

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

section 754 election can provide buyer with a fair market value in the basis of the ... Special rules apply to a partnership merger under Section 708(b)(2)(A);

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

Date added: February 2, 2012 - Views: 22

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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

http://treasury.state.tn.us/revenue/rulings/fae/11-45fe.pdf

Date added: August 2, 2015 - Views: 1

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Taxation of Partnerships and LLCs Complex Tax...

Construct of a Technical Termination Final and Initial Year Returns ... Section 754 Election / Basis Adjustments under Sections 743 and 734 3.

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

Date added: October 24, 2013 - Views: 3

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Optional Adjustments to Basis of Partnership...

The Section 754 Election ... A transferee partner who has a special basis adjustment under section 743(b) shall attach a statement to his income tax return,

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

Date added: July 21, 2013 - Views: 1

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LATE ELECTIONS AND SECTION 9100 – DON’T CALL YOUR...

rules, including a section 501(c)(3) election under section 508 and a homeowners association under section 528; partnership basis adjustments under section 754;

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

Date added: December 10, 2013 - Views: 3

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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: 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: 2

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112 JTAX 239 Page 1 (Cite as: 112 JTAX 239, 2010...

Section 754 election is generally effective for the tax year in which it is made, and all subsequent tax years unless re-voked by the partnership.

http://www.fdh.com/news/data/0026/_res/id=sa_File1/JTAX%20Article%20for%20website%20_01001846__part_2.pdf

Date added: October 26, 2011 - Views: 9

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SOLVING SECTION 734(b)

Section 734(b) is one such rule. This section seeks to preserve the right amount ... Partnerships wishing to make the adjustments must make a section 754 election.

http://www.jstor.org/stable/20772688

Date added: October 11, 2013 - Views: 1

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Acquisition Planning Strategies - San Jose State...

• Acquisition of partnership interest with §754 election ... Section 754 Election • Adjusts basis of purchaser’s share of partnership’s

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

Date added: October 4, 2012 - Views: 2

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15134 Federal Register / Vol. 67, No. 61 / Friday,...

15134 Federal Register / Vol. 67, No. 61 / Friday, March 29, 2002 / Proposed Rules interest in a partnership that owns stock ... section 754 election had been in effect.

http://www.msha.gov/REGS/FEDREG/ANPRM/2002/02-7467.PDF

Date added: May 17, 2012 - Views: 5

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T ax Controversy Corner - Kostelanetz & Fink, LLP

T ax Controversy Corner ... a Code Sec. 754 election and directed the partnership to ... of the election and the application for Section 9100 relief,

http://www.kflaw.com/siteFiles/News/5A37652D79AA7B92CC04B7DC728054CB.pdf

Date added: June 27, 2015 - Views: 1