Simple Substantial Economic Effect Regulatory Compliance
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Instructor Profile David Randall Jenkins, Ph.D., received his doctorate in accounting and a master's in accounting with an emphasis in tax from the University of Arizona. He has taught financial, managerial, and tax accounting courses at both the graduate and undergraduate levels. Dr. Jenkins is an AACSB academically qualified business school and tax professor owing to his peer reviewed journal article publications. He currently provides tax and business consulting services through his company, Algorithm LLC (algorithm-llc.com), an IRS Approved Continuing Education Provider.
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Description The Internal Revenue Service and many commentators consider Section 704(b)´s substantial economic effect regulations among the most complex. This webinar overviews how partnership special allocations Treasury Regulations enable simple compliance through economic effect equivalence and substantiality´s conclusive presumption
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Why should Attend
This webinar is designed for practitioners as an overview to the simplicity of substantial economic effect regulatory compliance through economic effect equivalence and substantiality´s conclusive presumption. Attorneys, CPAs, enrolled agents, and other tax practitioners will be able to add important transaction-structuring special allocations to their arsenal of tools designed to improve client welfare.
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Objectives
Understanding the history and background of the special allocations´ substantial economic effect requirement since it was first introduced in the Internal Revenue Code of 1954. Understanding the necessary elements of the economic effect trinity: capital account maintenance, liquidation in accordance with capital account balances, and required capital account deficit restoration. Understanding Treas. Reg. Section 1.704-1(b)(2)(ii) (i) Economic Effect Equivalence. Understanding the simplicity of Treas. Reg. Section 1.704-1(b)(2)(iii)(c)(2)´s substantiality conclusive presumption. Understanding necessary partnership agreement special allocation substantial economic effect provisions.
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Who can Benefit
Attorneys Certified Public Accountants Enrolled Agents Other Tax Professionals
www.onlinecompliancepanel.com | 510-857-5896 | customersupport@onlinecompliancepanel.com
How this Webinar Works
Username and Password will be sent to you 24 hours prior to the webinar Presentation handouts in pdf format will be mailed to you Login to the session using the username and password provided to you Get answer to your queries through interactive Q&A sessions via chat
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