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Partnership Allocations: How Section 704 Works

PARTNERSHIP ALLOCATIONS: HOW SECTION 704 WORKS

Cost Free
Presentation Length 2.0 hours

Recorded DateMarch 17, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

At some point, all accountants see the section of a Partnership or Operating Agreement titled “Allocations.” Most of the time, the provisions are two pages of boilerplate riddled with citations to the Treasury Regulations. But what does the language actually mean, and how does it affect the preparation of IRS Form 1065 or planning for transactions involving tax partnerships? What’s the difference between so-called “safe harbor allocations” and “non-safe harbor allocations,” and why would a partnership use one or the other? What is “partnership minimum gain,” anyway? This webinar explores Section 704 in moderate detail and will familiarize attendees with the topic of partnership allocations.

PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Matthew E. Rappaport concentrates his practice in Taxation as it relates to Real Estate, Corporations, Partnerships, and Trusts & Estates. He advises clients regarding tax planning and structuring for generational wealth transfer, commercial real estate enterprises, business transactions, and cross-border considerations. He primarily advises real estate professionals, financial professionals, and closely held business owners. He also functions like a subcontractor for other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise.

Mr. Rappaport graduated from Washington University in St. Louis in 2007, cum laude, with an undergraduate degree in Political Science. His undergraduate thesis was a cross-sectional analysis of the corporate culture of the privately held financial firm Edward Jones. He received his Juris Doctor and Master of Laws in Taxation from Georgetown University Law Center in 2011. Mr. Rappaport is licensed to practice in New York and is an active member of the Nassau County Bar Association, the New York State Bar Association, and the American Bar Association. He was the Co-Vice Chair of the Tax Committee of the Nassau County Bar Association from June 2015 until June 2016.

He serves on the Sales, Exchanges, and Basis Committee of the American Bar Association Section of Taxation. Mr. Rappaport has authored articles for the Nassau Lawyer, Thomson Reuters’ Journal of Real Estate Taxation, The Tax Adviser, Bloomberg BNA’s Tax Management – Real Estate Journal, and the Journal of Taxation of Investments. He has spoken at the request of the American Bar Association, the National Conference of CPA Practitioners, the Financial Planning Association, Strafford Publications, the School of Accounting at LIU Post, and a wide variety of law, accounting, and wealth advisory firms. He is a founder of the young professionals networking group Hydra Collective.

About Our Presenter

Falconrappaport logo
Matthew E. Rappaport concentrates his practice in Taxation as it relates to Real Estate, Corporations, Partnerships, and Trusts & Estates. He advises clients regarding tax planning and structuring for generational wealth transfer, commercial real estate enterprises, business transactions, and cross-border considerations. He primarily advises real estate professionals, financial professionals, and closely held business owners. He also functions like a subcontractor for other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise.