Unlike the standard partnership tax class, this two day seminar focuses upon the specific issues encountered by oil and gas partnerships. The Federal income tax treatment of an oil and gas partnership is unique in the sense that the tax rules of subchapter K of the IRC are applied in a different manner to oil and gas exploration and production than any other type of business. This uniqueness stems from the fact that Sec. 613A requires that the basis of oil and gas property is held outside of the partnership by each partner and the partner computes depletion, gain and loss independent of the partnership.
No other extractive industry works this way. For example, coal, iron, etc. – the partnership holds the basis of the mineral property and computes gain and loss on its mineral properties and then allocates depletion, gains and losses to the partners. This has many tangent effects that are explored by this seminar. Having to go through this maze of regulations and rules alone can be a bit confusing – after all it took the IRS over 15 years to issue final regulations under Sec. 613A – primarily because of the partnership issues.
To unravel this byzantine maze, this seminar addresses the common and often intricate transactions faced by oil and gas tax partnerships using a building block approach. Topics include:
- An Introduction to Oil and Gas Partnerships
- Forming an Oil and Gas Partnership
- Operating Issues of an Oil and Gas Partnership
- Sec. 704(b) Special Allocations
- Allocations Required from Contributed Oil and Gas Property - Sec. 704(c)
- Partner - Partnership Transactions
- Sale or Exchange of an Oil and Gas Partnership Interest
- Operating Distributions of Oil and Gas Partnerships
- Liquidation of a Partnership Interest Held in an Oil and Gas Tax Partnership
New Dates to be Announced