Sample Section 754 Election Statement

734 b and 743 b to adjust the basis of partnership property as provided by irc sec.
Sample section 754 election statement. Election to adjust the basis of partnership property under internal revenue code section 754 sample llc with 754 llc 235 n edgeworth st greensboro nc 27401 employer identification number. Pursuant to irc section 461 h 3 the s corporation hereby elects to adopt the recurring item exception as a method of accounting. A valid election under sec.
Election to adopt recurring item exception. Statement of section 754 election i. Two statements should be attached to the return for the taxable year during which the distribution or transfer occurs.
754 could substantially benefit the owners of entities treated as partnerships for tax purposes i e general partnerships limited partnerships limited liability companies limited liability partnerships and other multimember entities for which a check the box election was made to treat the entity as a partnership for tax purposes or for which the default classification in the absence of an election is to treat the entity as a partnership because it allows a. Pursuant to irc section 1 754 1 b 1 the partnership hereby elects to adjust the basis of the partnership property for the tax year ended 12 31 08. The purpose of a section 754 election is to reconcile a new partner s outside and inside basis in the partnership.
18 adopt recurring item exception sec 461 h 3 title. This will print an election statement. Partnership name partnership address.
Section 754 election 1065 only under section 754 a partnership may elect to adjust the basis of partnership property when property is distributed or when a partnership interest is transferred. Utilizing this election can accelerate deductions. 1 754 1 b 1 to apply the provisions of irc secs.
Section 754 provides that if a partnership files an election section 754 election in accordance with regulations prescribed by the secretary the basis of partnership property shall be adjusted in the case of a distribution of property in the manner provided in section 734 and in the case of a transfer of a partnership interest in the manner provided in section 743. The partnership referred to in this paragraph is. In the event of a transfer of all or part of the interest of a member at the request of the transferee or if in the best interests of the company as determined by the members as a major decision the company shall elect pursuant to section 754 of the code to adjust the basis of company property as provided by sections 734 and 743 of the code and any cost of such election or cost of administering or accounting for such election shall be at the sole cost and expense.