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2025-07-21 08:25:00

19.5 Credits

Partnership taxation fundamentals under Subchapter K, covering entity classification, formation, capital accounts, allocations, and operational tax rules.

2025-07-21 08:25:00

19.5 hours

Partnership taxation fundamentals under Subchapter K, covering entity classification, formation, capital accounts, allocations, and operational tax rules.

2025-07-21 08:25:00

19.5 hours

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

Key topics that will be covered

What will you learn

Attorneys will learn foundational partnership taxation concepts including entity classification, formation rules, capital accounts, allocations under Section 704(b), and Section 704(c) methods.

What will you gain

Attorneys will gain practical knowledge for advising clients on partnership formation, liability allocation, taxable year requirements, and the substantial economic effect safe harbor.

Entity Selection
Compare partnerships and corporations for tax-free formation, distributions, and sales.
Classification Rules
Apply check-the-box regulations to determine partnership, corporation, or disregarded entity status.
Basis Concepts
Track inside basis and outside basis separately throughout partnership operations.
Capital Accounts
Maintain capital accounts to reflect partner equity and liquidation entitlements.
Section 704(b)
Ensure allocations have substantial economic effect or reflect partner interest.
Section 704(c)
Allocate built-in gain or loss using traditional, curative, or remedial methods.

What will you learn

Attorneys will learn foundational partnership taxation concepts including entity classification, formation rules, capital accounts, allocations under Section 704(b), and Section 704(c) methods.

What will you gain

Attorneys will gain practical knowledge for advising clients on partnership formation, liability allocation, taxable year requirements, and the substantial economic effect safe harbor.

Agenda

Session 1

Introduction, Choice of Entity and Partnership Formation

Session 2

Partnership Operations and Special Allocations Under 704(b)

Session 3

Nonrecourse Debt Allocations and Deduction Rules

Session 4

Current and Liquidating Partnership Distributions

Session 5

Partner-Partnership Transactions and Disguised Sales

Session 6

Sales and Purchases of Partnership Interests

Session 7

Retirement and Death of a Partner

Session 8

Hot Topics in Partnership Taxation Today

Session 9

The Troubled Partnership: Workouts and Foreclosures

Session 10

Summing Up: Partnership Returns and Agreement Review

clock 8:25 am - 12:00 pm EST

Introduction, Choice of Entity and Partnership Formation

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This foundational session covers essential choice of entity considerations, comparing partnerships to corporations across formation, operations, and exit strategies. Participants will explore entity classification rules, the check-the-box regulations, formation nonrecognition under Section 721, and establishing beginning capital accounts, basis, taxable year, and accounting methods.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 1:00 pm - 4:30 pm EST

Partnership Operations and Special Allocations Under 704(b)

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session examines how partnership operations affect tax and book capital accounts and partner basis throughout the partnership’s life. Participants will master Section 704(b) allocation rules, the substantial economic effect safe harbor requirements, target allocations, and the critical distinction between economic and tax allocations under Section 704(c).

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 8:30 am - 11:45 am EST

Nonrecourse Debt Allocations and Deduction Rules

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session addresses the complex rules governing allocations of nonrecourse debt among partners and the special regulations for nonrecourse deductions. Participants will learn how minimum gain chargeback provisions work and understand the policy rationale for treating nonrecourse liabilities differently from recourse obligations.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 12:45 pm - 2:00 pm EST

Current and Liquidating Partnership Distributions

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session covers the tax consequences of both current and liquidating distributions from partnerships to partners. Participants will analyze disproportionate distribution rules, the treatment of hot assets, and how distributions affect both inside and outside basis calculations.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 2:15 pm - 4:30 pm EST

Partner-Partnership Transactions and Disguised Sales

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session explores the complex rules governing transactions between partners and their partnerships, with emphasis on disguised sale provisions. Participants will learn to identify when contributions and distributions may be recharacterized as taxable sales and understand the two-year presumption rules.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 8:30 am - 10:00 am EST

Sales and Purchases of Partnership Interests

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session examines the tax consequences when partnership interests change hands through sales and purchases. Participants will analyze gain characterization rules, hot asset provisions under Section 751, and the Section 754 election for basis adjustments.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 10:15 am - 12:00 pm EST

Retirement and Death of a Partner

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session addresses the unique tax consequences when partners retire or die, including the treatment of payments under Section 736. Participants will explore timing and character issues, the distinction between Section 736(a) and 736(b) payments, and planning opportunities for retiring partners and their successors.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 1:00 pm - 2:00 pm EST

Hot Topics in Partnership Taxation Today

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session provides an overview of recent developments in partnership tax law and emerging trends in partnership structures. Participants will learn about current IRS guidance, recent court decisions, and evolving uses of partnerships in modern transactions.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 2:15 pm - 3:30 pm EST

The Troubled Partnership: Workouts and Foreclosures

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This session addresses tax issues arising when partnerships face financial distress, including workouts, foreclosures, and deeds in lieu. Participants will analyze the consequences of debt cancellation, abandonment of partnership interests, and strategies for managing tax liability in troubled situations.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

clock 3:30 pm - 4:30 pm EST

Summing Up: Partnership Returns and Agreement Review

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

This capstone session walks through a partnership tax return and sample partnership agreement, emphasizing tax-sensitive provisions. Participants will apply their knowledge to real-world documents covering capital account maintenance, book-ups, Section 704(c) method choices, and liquidation provisions.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

01 10
Prev
Next

speakers

Joe Ervin

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Kevin Foley

Reminger Co
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Grant H. Lawson

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Charles R. Bogle

Morgan, Lewis & Bockius LLP

Justin S. Cohen

Hughes Hubbard & Reed LLP

Sean Austin

Managing Director, KPMG

Charles Kaufman

Managing Director, KPMG

Alan Kravitz

Hughes Hubbard & Reed

Andrew Lau

MN8 Energy

Olivia Schomburger

Clifford Chance

Hannah Richard

Clifford Chance

Lance Parker

BDO USA

Ira Aghai

Clifford Chance

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of Bias, etc.)
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Why Attend

Why this 
program matters

Mastering Subchapter K is critical because partnerships represent trillions in assets and income requiring proper tax planning, compliance, and strategic structuring.
4.5M+
Partnership tax returns filed for Tax Year 2023, representing a significant and growing compliance burden for practitioners.
$57T
Total assets held by U.S. partnerships in 2023, a 9.1% increase from the prior year, underscoring the massive scope of partnership tax planning.
~50%
Of the 4 million U.S. partnerships are real estate partnerships, making Subchapter K knowledge essential for commercial real estate practitioners.
$2T+
Pass-through income allocated to partners in Tax Year 2023, requiring practitioners to understand complex allocation and distribution rules.

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No Required
Minnesota
Approved
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Approved
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs