CPA / Partnership Tax Specialist for IRC §721 Real Estate Contribution and Partnership Basis Model

Overview: We are forming a real estate investment structure involving the contribution of an existing income-producing property into a newly formed partnership/LLC in exchange for equity under IRC Section 721. The contributing owner currently holds the property through an existing LLC and has an established tax basis, depreciation history, liabilities, and balance sheet. We need an experienced CPA or partnership tax specialist to analyze the transaction and model the resulting tax consequences and allocations. This is not a tax return preparation engagement. We need transaction structuring and partnership tax analysis. Scope of Work: The selected professional will: Review the contributing LLC's balance sheet and tax basis information Analyze the proposed IRC §721 contribution Calculate: - Contributing partner's outside basis - Partnership inside basis - Capital accounts (book and tax) - Liability allocations under IRC §752 Evaluate whether liabilities create gain recognition concerns Analyze §704(c) implications and built-in gain allocations Model future depreciation and loss allocations among partners Evaluate potential disguised sale issues, if applicable Coordinate assumptions with legal counsel and fund formation counsel as needed Provide a written memorandum and supporting calculations Deliverables: We expect: 1. Written tax analysis memorandum 2. Basis and capital account schedules 3. Liability allocation analysis 4. §704(c) allocation recommendations 5. Sample allocation model showing future depreciation, losses, and sale proceeds 6. Recommendations regarding partnership agreement tax provisions Ideal Candidate CPA with strong partnership taxation background Significant experience with IRC §§721, 704(b), 704(c), and 752 Experience with real estate syndications, private funds, UPREITs, DSTs, or complex partnership structures Comfortable reviewing operating agreements and coordinating with legal counsel Able to explain complex partnership tax concepts clearly Please describe your experience with similar transactions and provide examples of the types of partnership contribution structures you have worked on.