OPTIMA 704(c)

OPTIMA 704(c) comprehensively addresses taxation issues in partnerships with contributed, §704(c) properties.

At the basic level, OPTIMA solves the problem of §704(c) compliance, systematically addressing the following issues:

• Allocation of depreciation expenses, following the remedial, traditional, and traditional with back-end curative methods.
  
• Allocation of gains relating to the dispositions of assets.
  
• Allocation of miscellaneous income and expenses.
• Allocation of §752 nonrecourse liability.
  
• Transfers of partnership units.
  
• Redemptions of partnership units.
  
• Revaluation of partnership property.

Beyond tax compliance, OPTIMA enables prospective analyses that were previously considered impossibly difficult:

• What is the most tax-favorable combination of §704(c) methods for our newly formed partnership?
  
• What will be the gain consequences if we liquidate a number of properties?
  
• What effect will revaluations have on our §752 debt allocations?
  
• Will 704(b) amortization create partnership minimum gain on leveraged properties with large §704(c) gains?

For problems that require considerable expertise in both tax theory and data analysis, Crimson Tree Software and KPMG offer consulting services using our proprietary software models.

For more information about OPTIMA 704(c) and other topics, please contact us.