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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: 143

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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: 38

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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

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

Date added: January 29, 2012 - Views: 19

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

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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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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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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Death of a Partner and § 754 Elections - Greenberg...

Death of a Partner and §754 Elections: Income ... Section 754 addresses this "basis mismatch" by allowing the partnership to ... §754 election for the year of ...

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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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: 14

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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: 28

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

Foreign Tax Credits: Focus on Section 901(m) Under ... – Any acquisition of an interest in a partnership which has a section 754 election in effect – Any ...

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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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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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://www.tn.gov/revenue/rulings/fae/11-45fe.pdf

Date added: October 16, 2012 - Views: 2

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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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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 Department of the...

without making a section 754 election, ... of the Income Tax Regulations provides that an election under section 754 is made in a written statement filed with the ...

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

Date added: March 16, 2013 - Views: 7

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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: 4

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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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Navigating the Tax Rules Pertaining to...

partnership makes a Section 754 election to adjust the basis of its assets.14 If the partnership has made a Section 754 election, it may increase (or decrease) the

http://www.sdbar.org/cle/arntd2011taxupdateoutline.pdf

Date added: October 22, 2012 - Views: 14

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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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What’s News in Tax

As noted above, a technical termination under section 708(b)(1)(B) ... section 754 election is applicable to all distributions of property by the partnership

http://www.us.kpmg.com/microsite/taxnewsflash/2011/Jan/Partnership_Short_Year.pdf

Date added: December 22, 2011 - Views: 31

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Structuring a Buyout — Sale versus Redemption

ISSUE TO CONSIDER SALE REDEMPTION Governing Code Section(s) §741, §751 §736, §751 ... however, is dependent on a valid §754 election being in place.

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

Date added: February 12, 2015 - Views: 1

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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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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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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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Taxation of Partnerships and LLCs Complex Tax...

1. Actual Termination of a Partnership – Section 708(b)(1)(A) ... Section 754 Election and Basis Adjustments Depreciation: Special Issues

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

Date added: October 24, 2013 - Views: 3

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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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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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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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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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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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THE SECTION 734(b) BASIS ADJUSTMENT NEEDS REPAIR

When an election under section 754 is made, ... adjustment under section 734(b) or section 743(b) occurred but was not made because an election

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

Date added: August 12, 2013 - Views: 1

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Optional Basis Adjustments Solutions

Section 743(b)(1) requires that a partnership for which an election under §754 is in effect, ... §743(b) adjustment $20,000 If a §754 election is in effect, ...

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

Date added: November 10, 2011 - Views: 17

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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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Notice 201444 - Foreign tax credits and section...

credits related to a “covered asset acquisition” (CAA). ... interest in a partnership for which a section 754 election is in effect; and (3) any

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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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: 20

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Consequences of Liquidating Distribution

5 Partnership Results of Distributions Sec. 754 Election in Effect zIf the basis of the assets distributed must be reduced – – Excess is added to the basis of the

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

Date added: December 6, 2012 - Views: 1

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Reg. Section 301.9100-2(d) - Tax Reduction Letter...

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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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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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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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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T ax Controversy Corner

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

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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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Internal Revenue Service Department of the...

Department of the Treasury Washington, DC 20224 ... without a § 754 election. LAW AND ANALYSIS Section 754 provides that a partnership may elect to adjust the basis of

http://www.irs.ustreas.gov/pub/irs-wd/0022040.pdf

Date added: June 27, 2015 - Views: 1

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AICPA Top 10 Merger and Acquisition Tax Issues...

Top 10 Merger and Acquisition Tax Issues ... an IRC Section 754 election in the case of a partnership. The stock of a C Corp target company

http://www.blakechristian.com/downloads/library/top10.pdf

Date added: February 2, 2012 - Views: 11

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Section 1. Chapter 754, 1971 Session Laws, is...

election. Sec. 2. The second sentence of Section 2, Chapter 754, 1971 Session Laws, is amended by deleting the words and punctuation "and four members of the Board of

http://www.ncga.state.nc.us/enactedlegislation/sessionlaws/pdf/1973-1974/sl1973-898.pdf

Date added: June 27, 2015 - Views: 1

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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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L604 Session 10 Handout - Washington Institute for...

Session 10 Problems 10.1 Holly ... Section 754 election in effect and was formed ten years ago. a. What are the tax consequences of a distribution of $60,000 of cash ...

http://www.wsltax.org/assets/l604%20session%2010%20handout.pdf

Date added: June 27, 2015 - Views: 1

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~tatt In([ourt of ~pptal~ - Minnesota

Section 754 election is made by attaching an election form and a Section 743(b) adjustment statement to the partnership's timely filed tax returns. Respondents allege

http://mn.gov/web/prod/static/lawlib/live/briefs/pdfs/a101439caa1.pdf

Date added: May 9, 2013 - Views: 5