A pre-recorded streaming VIDEO replay of one session from the June 2017 live seminar, 69th Annual Virginia Conference on Federal Taxation.
Sponsored by The University of Virginia Tax Foundation Cooperating Organizations: VSCPA, VBA, VSB, UVa McIntire School of Commerce, UVa School of Law
Lawyers love target allocations because they think such language is largely boilerplate and low risk, but somebody (usually an accounting firm) still has to interpret the allocations in light of the partnership’s actual year-end facts and put numbers on a tax return. Using real-world examples, this session focuses on target allocations from the perspective of the accounting firm that must interpret them in light of the partnership’s distribution waterfall. The panelists will walk through each step in the process, starting with analyzing relevant partnership provisions and ending with the Form 1065 allocations, and highlight commonly encountered drafting ambiguities.