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Form 15254: Request for Section 754 Revocation

Live Webinar
August 11, 2022
1:00 pm ET (12 pm CT, 11 am MT, 10 am PT)
1 hour 40 minutes
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Basics of Section 754 Election
Why Make a Section 754 Election
  • Equalizes Inside and Outside Income Tax Basis
  • Avoids Premature Recognition of Gain From Sale of Partnership Assets
Elements of a Section 754 Election
  • Applies to All Subsequent Periods
  • Results in Increase or Decrease in Inside Tax Basis
Substantial Built-In Loss Rule
  • Prevents Double Benefit of Built-in Losses
  • Mandatory Step Down
  • New Rules for Transfers After 12/31/17
Section 754 and Distributions of Property (Section 734(b)
Termination of Partnerships Pre-2018
  • Ceases Activity
  • Technical Termination
  • Ability to Make New Elections
  • Challenges and Opportunities of Technical Terminations
Terminations After 12/31/17
  • No Longer Technical Terminations
  • No Longer Able to Terminate Elections
Revoking the Section 754 Election After 2017
  • New Form - 15254
  • Examples of Reasons to Revoke Elections
  • Planning for Acceptance
  • Other Considerations


Live Webinar$199Register Now