Introduction to Partnerships Taxation 2025 (presented by NYU School of Professional Studies) [Day 3]

This foundational session covers choice of entity considerations, entity classification rules, and restrictions on partnership status. Attendees will learn about partnership formation including nonrecognition rules, beginning book and tax capital accounts, basis calculations, taxable year selection, and accounting methods.

Explore how partnership operations affect tax and book capital accounts along with partner basis calculations. This session provides detailed coverage of special allocations and their requirements for substantial economic effect under the regulations.

This session examines the complex rules governing allocations of nonrecourse debt among partners and the treatment of nonrecourse deductions. Attendees will learn about minimum gain, minimum gain chargeback provisions, and partner nonrecourse debt concepts essential for real estate and leveraged partnerships.

Analyze the tax consequences of current and liquidating distributions from partnerships to partners. This session covers basis adjustments, disproportionate distributions, and the application of Section 732 allocation rules for distributed property.

Examine the rules governing transactions between partners and partnerships, including disguised sales under Section 707(a)(2). Learn to identify when contributions followed by distributions may be recharacterized as taxable sales and the two-year presumption rules.

This session covers the tax treatment of partnership interest transfers under Section 741, including hot asset rules under Section 751 and holding period considerations. Special attention is given to Section 743(b) basis adjustments, effectively connected income rules for non-U.S. persons, and withholding requirements under Section 1446(f).

Explore the consequences under Subchapter K when partners retire or pass away, including Section 736 payment classifications. This session addresses timing and character of income issues, successor basis rules, and special considerations for two-person partnerships.

Review recent developments including the One Big Beautiful Bill Act amendments to Section 707(a)(2) and basis shifting transaction guidance under Notice 2025-23. This session also covers ongoing litigation regarding the limited partner exception for self-employment tax and final regulations on Section 752 recourse liabilities.

Address the tax consequences when partnerships face financial distress, including debt forgiveness, cancellation of debt income, and Section 108 exclusions. Learn about debt-for-equity exchanges, debt modifications, foreclosures, deeds in lieu, and abandonment of partnership interests.

Work through a partnership tax return and examine key provisions in sample partnership agreements. This practical session emphasizes tax-sensitive provisions including capital account maintenance, book-ups, Section 704(c) allocation method elections, and liquidation provisions.