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Targeted partnership tax allocations are a popular choice for allocating income and loss among partners. Tax counsel and advisers must provide clients with guidance on whether this method will capture all allowed benefits.
A primary concern plaguing taxpayers is compliance with IRC 704(b) and its complicated regulations. Advisers and counsel must grasp the nuances of these complex rules when drafting targeted tax allocation provisions.
Tax advisers and counsel must also differentiate between targeted and regulatory allocations. For example, target allocation agreements may not satisfy regulatory safe harbors but can still meet the economic effect equivalence test or the partners' interest in the partnership test. Failing to come under regulatory safe harbors may impact the availability of other favorable rules.
Listen as our experienced panel guides you to determine when targeted allocation provisions are beneficial and on drafting best practices. The panel will explain how to comply with IRC 704(b), including its substantial economic effect standards, and how to choose between targeted and regulatory allocations.
Key topics include:
CLE credit available.