Paul L. Caron
Dean


Monday, March 23, 2020

Free Online Content: Business Taxation/Subchapter K

CoronavirusIf you are looking for “plug and play” online content for your business taxation or partnership taxation course, Professor Cass Brewer, Georgia State University College of Law, is offering numerous videos that he created for his fall 2019 online Partnership & LLC Taxation course. See the table below for details. Brewer warns, “Caveat emptor: The videos are far from perfect because they were created for the first iteration of my online Partnership & LLC Taxation course. Some of the videos have technical glitches, and the closed captions for many of the videos contain typos and other errors. In a pinch, however, you may find the videos useful to finish out the semester.”

Quick Links to Online Materials Regarding Subchapter K (Partnership & LLC Taxation):

Topic

IRC Sections

Video Link

Definition of a Partnership and Choice of Entity

IRC §§ 761(a); 7701(a)(3); skim IRC § 199A

Video 1: Definition of Tax Partnership

Video 2: Types of State-Law Business Organizations

Video 3: Four Federal Income Tax Regimes

Video 4: Classification (a/k/a “Check-the-Box”) Rules

Video 5: Tax Hieroglyphics

Partnership Formation: Basics

IRC §§ 704(c)(1)(A) & (c)(3), 705(a), 721, 722, 723, 731(a)(1), 733

IRC §§ 1245(b)(3), 1223(1) & (2)

Video 1: Introduction

Video 2: AB, LLC Formation

Video 3: Formation/Conversion

Video 4: Formation/Conversion

Video 5: Formation/Conversion

Partnership Formation: Advanced (Special Rules, Liabilities, and Gain Recognized)

IRC §§ 704(c)(1)(A) & (c)(3), 724

IRC §§ 731(a)(1), 752(a)-(c)

Video 1: IRC §§ 704(c) and 724

Video 2: IRC §§ 704(c) and 724 Illustrated

Video 3: Formation and Liabilities Part One

Video 4: Formation and Liabilities Part Two

Video 5: Formation (Gain Recognized)

Partnership Operations: Taxable Years, Methods of Accounting, Allocations, Outside Basis Adjustments, Outside Basis Loss Limitation

IRC §§ 446(a)-(c), 701, 702(a)-(b), 703, 704(a) & (d)

IRC §§ 705(a)(1)-(2), 706(a)-(b)(1)(B)

Skim IRC §§ 448(a)-(c), 6031(a)-(b)

Video 1: Taxable Years and Methods of Accounting

Video 2: Allocations of Tax Items

Video 3: Outside Basis Adjustments and Loss Limitation

Substantial Economic Effect

IRC § 704(a) & (b)

Video 1: Introduction

Video 2: Analysis of Orrisch

Issuing Partnership Interests in Exchange for Services

IRC §§ 83(a)-(c), (h); 721; 1061

Video 1: Introduction

Video 2: Capital v. Profits Interests

Video 3: IRC § 1061 (“Carried Interests)


Built-In Gain (Loss), Revaluations, Tax/Book Depreciation (Traditional Method), and Anti-Character Conversion Rules

IRC § 704(c)(1)(A) & (3)

IRC § 704(b)

IRC § 724(a)-(c)

Video 1: Introduction

Video 2: Book/Tax Gain (Loss) Allocations

Video 3: Revaluations

Video 4: Reverse 704(c) Allocations

Video 5: Anti-Character Conversion (§ 724)

Partnership Liabilities: Recourse v. Nonrecourse

IRC §§ 704(c)(1)(A) & (3); 752(a)-(c)

Video 1: Recourse v. Nonrecourse Debt

Video 2: Nonrecourse Deductions

Video 3: Liability Sharing Rules of IRC 752

Video 4: Recap

Transfers of Interests

IRC §§ 705(a); 706(c); 741; 751(a), (c), (d), (f); 752(d)

Video 1: In General

Video 2: Seller’s Perspective

Video 3: Buyer’s Perspective

Current and Liquidating Distributions of Cash

IRC §§ 731-735

Video: In General

TaxProf Blog coronavirus coverage:

https://taxprof.typepad.com/taxprof_blog/2020/03/free-online-content-business-taxationsubchapter-k.html

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