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September 22, 2017
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October 04, 2017
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October 26, 2017
4:00PM - 6:00PM ET



Course Description

Partnership tax allocations may be made by agreement provided those allocations have substantial economic effect. The common thread in IRS-developed safe harbors for economic effect is the Section 704(b) capital account provisions. Section 704(b) capital is also the basis for determining Section 704(c) allocations of built-in gains and losses of contributed property. This course provides an in-depth analysis of how the capital account provisions apply to different transactions and illustrates how the capital accounts can be used to track allocations.


Jim R. Hamill, CPA, PhD

Jim Hamill is the Director of Tax Practice at Reynolds, Hix & Co., P.A., in Albuquerque, New Mexico, where he provides tax consulting services for real estate, partnership, and corporate clients and also provides estate planning services for families. He is also a managing member of Exchange Facilitators, LLC, which provides qualified intermediary and exchange accommodation titleholder services for Section 1031 exchanges. Jim is the author of over 30 CPE courses and more than 100 articles in professional tax journals and writes a weekly column on tax issues for the Albuquerque Journal. He has lectured on structuring tax transactions throughout the country for over 25 years and does web-based learning for CCH. Jim has taught classes for four of the national CPA firms as well as many other organizations. He is a CPA in New Mexico, a past Chair of the New Mexico Society of CPAs, has 34 years of experience as a tax practitioner, and also taught university tax courses for more than 20 years.

Course Specifics

May 24, 2016

Compliance Information

IRS Provider #: 0MYXB IRS Course ID: 0MYXB-T-01030-16-O IRS Federal Tax Update Credits: 2
CTEC Provider #: 2071 CTEC Course ID: 2071-CE-0996 CTEC Federal Tax Update Credits: 2 Qualifies for CA Fraud: No

Learning Objectives

Upon successful completion of this course, participants will be able to:

  • Identify the types of agreements that provide for Section 704(b) capital maintenance
  • Determine how to make adjustments to Section 704(b) capital in common transactions
  • Distinguish allocations subject to the economic effect test from built-in gain or loss allocations

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