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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Section 704(c) Capital Account Book-Ups: Revaluation of Partnership Assets

Triggering Events for Revaluations, Effects of Revaluations on Allocations of Tax Items

$197.00

This course is $0 with these passes:

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Description

Maintaining partners' capital accounts often presents significant challenges for even the most experienced practitioners. It can be particularly challenging to understand the capital account maintenance rules and Section 704(c) effects in situations where one or more partners have contributed built-in gain or built-in loss property.

Under certain circumstances, a partnership may be entitled to revalue (restate) the partners' capital accounts to FMV, commonly called a "book-up" or “book-down” of the partners' capital accounts. A book-up can be beneficial to maintain the intended economics of the partnership. But it can also result in complex Section 704(c) consequences. The current requirement to report unrecognized 704(c) gains on Schedule K-1 has made understanding these transactions critical for tax professionals.

Listen as our panel of experienced tax practitioners provides a practical guide to Section 704 capital account book-ups.

Presented By

Noel P. Brock
Assistant Professor
Eastern Michigan University

Professor Noel P. Brock is an associate professor at Eastern Michigan University where he teaches and researches in all areas of tax law with specific emphasis on business (partnership, corporate and international) taxation. He teaches primarily in the Master of Tax Program. Prior to entering academia in January 2012, he spent over 18 years in private practice—most recently, he was a partner and the partnership tax practice leader in the Washington National Tax Office of Grant Thornton LLP. Prior to joining Grant Thornton LLP, Professor Brock practiced in with international accounting and law firms where he represented clients in transactional tax matters including partnership, international, corporate and financial products transactions. Since entering academia, Professor Brock has remained engaged in practice on a part time basis and is currently a Principal with Holthouse Carlin & Van Trigt LLP.





Professor Brock’s research focuses on business taxation and accounting education. Among the awards he has received since entering academia include being awarded researcher of the year twice. His research has been published in in leading international and national journals, including The Tax Adviser, Journal of Accountancy, Journal of Passthroughs, Journal of International Taxation, Tax Notes, The Journal of Legal Tax Research, Practicing Law Institute, and CCH TAXES, The Tax Magazine, among others. His work been cited by other leading tax professionals and in major tax treatises.





Professor Brock has spoken at international, national and regional tax conferences, including the ABA Section of Taxation, The 67th Annual University of Chicago Federal Tax Conference, District of Columbia Bar, Strafford Publications, A.L.I. CLE, AICPA, Private Equity International, and the Atlanta Tax Forum.





Professor Brock also remains very active in both the AICPA (as former chair and associate member of the Partnership Technical Resource Panel) and the ABA (former chair of and current member of the Partnerships & LLCs Committee, and Member of the Corporate Taxation Committee).

Jose Carrasco
Managing Director
Grant Thornton

Mr. Carrasco is a Managing Director in the partnership tax group of Grant Thornton’s Washington National Tax Office. He consults on technical issues affecting entities and their owners in transactions involving partnerships, such as mergers, disguised sales, leveraged acquisitions, and other partnership formation and liquidation events. Mr. Carrasco has authored and co-authored articles in publications that include the Tax Adviser and Bloomberg BNA’s Tax Management Memorandum and has presented at tax conferences, including for the American Bar Association Tax Section, District of Columbia Bar, Tax Executives Institute, and AICPA National Tax Conference. He is a Certified Public Accountant in the District of Columbia and North Carolina and is currently the chair of the AICPA’s Partnership Taxation Technical Resource Panel.

C. Todd Sinnett
Partner, Partnership Taxation
Grant Thornton

Mr. Sinnett is a partner in Grant Thornton’s partnership taxation business. He currently leads the firm’s Partnership Capital Account Maintenance services and National Partnership Team. Mr. Sinnett assists clients with tax consulting and tax compliance matters involving partnership annual operations and partnership transactions. Transactional tax matters include, but are not limited to, mergers, disguised sales and contributions involving non-cash property with significant built-in gains and losses, revaluation of partnership capital accounts, transfer of existing partnership interest, redemption of partners, issuance of partnership interest for services, and complete liquidations. Prior to joining Grant Thornton in 2002, Mr. Sinnett worked for Arthur Andersen. His experience includes construction, real estate, hospitality, consumer industrial products, energy, financial services, healthcare and technology.

Credit Information
  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Tuesday, November 30, 2021

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Overview of Section 704(b) capital account maintenance rules
  2. Overview of Section 704(c)
  3. "Forward" Section 704(c): contributions of built-in gain or built-in loss property
  4. Revaluations: when are book-ups or book-downs permitted, how are they done, and what are the consequences?
  5. "Reverse" Section 704(c): tax allocations following a book-up or book-down

The panel will review these and other key issues:

  • Understand the IRC 704(b) capital account maintenance rules
  • Ascertain the impact of contributions of built-in gain or built-in loss property
  • Identify the mechanics of book-ups and book-downs
  • Recognize the benefits and detriments of revaluations
  • Determine when unrecognized Section 704(c) gains and losses must be reported on Schedule K-1

Learning Objectives

After completing this course, you will be able to:

  • Identify triggering events that permit or require partnership asset revaluations for capital account book-up and book-down purposes
  • List the types of allocations allowed under Section 704(c)
  • Discern how to do an asset revaluation of intangibles and other difficult to value partnership property
  • Determine necessary substantiation requirements to support a reverse allocation
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of partnership structure, operating agreements and liquidation, including partner capital accounts, allocation and distributions; familiarity with the economic effect test; safe-harbor and non-safe harbor partnership agreements according to IRC 704

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .