[Webinar] IRC 754 Elections for Tax Counsel: Mastering Structuring Considerations of Basis Adjustments - Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections

March 13th, 1:00 pm - 2:30 pm EDT
March 13th, 2024
1:00 PM - 2:30 PM EDT
$ 347.00

An encore presentation with Live Q&A.

A 90-minute premium CLE/CPE video webinar with interactive Q&A

This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and partnership interests or property distributions; review the impact of the Section 754 election for individual partners and the partnership; and discuss structuring transactions to avoid unintended tax consequences.


Understanding the Section 754 election and its related basis adjustments is a critical skill for tax counsel serving as advisers to clients owning or managing partnerships. The election allows adjustments on the "inside basis" of assets the partnership owns.

The basis adjustment can have a significant impact when a partnership has an existing 754 election and admits a new partner, has one partner sell a partnership interest, or when the partnership makes a distribution to a partner. The election and adjustments can have different impacts on different partners, so tax advisers need to fully grasp the tax implications of making the election and utilizing the optional basis adjustments.

Tax advisers must understand not only the rules but also the practical calculations, allocations, and reporting mechanics of the 754 election. Counsel may be called upon to help make essential decisions with basis and depreciation issues and to help make complicated adjustment calculations.

Listen as our authoritative panel of tax advisers guides counsel through the basis adjustment rules, discusses the impact of the Section 754 election on individual partners and the partnership, and provides best practices for avoiding potential pitfalls of the election.


  1. The mechanics of a Section 754 election
  2. Inside and outside basis issues
  3. Ability to make 754 election due to a transfer
  4. What happens under 743(b) when a 754 election is made?
  5. 755 Basis adjustments
  6. Benefits


The panel will review these and other key issues:

  • Mechanics of making a Section 754 election at the partnership level and understanding "inside basis" vs. "outside basis"
  • Benefits and disadvantages of making the 754 basis election
  • Rules governing step-up and step-down basis adjustments
  • Rules for allocating basis adjustments
  • Impact of the 754 election on individual partners and the partnership
  • Common pitfalls in basis adjustments, and what practitioners can do to avoid these pitfalls

An encore presentation featuring Live Q&A.


Borden, Bradley

Professor Bradley T. (Brad) Borden
Professor of Law
Brooklyn Law School

Professor Borden’s research, scholarship, and teaching focus on taxation of real property transactions and flow-through entities (including tax partnerships, REITs, and REMICs). He teaches Federal Income Taxation, Partnership Taxation, Taxation of Real Estate Transactions, and Unincorporated Business Organizations, and he is affiliated with the Dennis J. Block Center for the Study of International Business Law. His work on flow-through and transactional tax theory appears in articles published in law reviews including Baylor Law Review, University of Cincinnati Law Review, Florida Law Review, Georgia Law Review, Houston Law Review, Iowa Law Review, Tax Lawyer, and Virginia Tax Review, among others. His articles also frequently appear in leading national tax journals including Journal of Taxation, Journal of Taxation of Investments, Real Estate Taxation, and Tax Notes.

Mandarino, Joseph

Joseph C. Mandarino
Smith Gambrell & Russell

Mandarino is a Partner in the Tax Practice of Smith, Gambrell & Russell, LLP. His practice focuses on corporate, tax and finance law. Mr. Mandarino is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino writes and speaks extensively on a wide range of business, tax and finance topics.



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