Partnership Taxation

Partnership Taxation

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Partnership Taxation is one of several releases from the LexisNexis Graduate Tax Series. This book contains a thorough discussion of the rules of partnership taxationa€”when a partnership exists, the tax treatment of contributions to a partnership, the basis of partnership assets and interests in a partnership, how income is allocated to the partners, the tax treatment of distributions, the consequences of partnership liabilities, partnership mergers, the retirement of a partner and dissolution of the partnership. There is also significant attention paid to the numerous qanti-abuseq rules that have been adopted by Congress and the IRS over the past several decades, including the disguised sale rules, the treatment of qmixing-bowlq transactions, the complex rules to prevent basis abuse, and the overriding qpartnership anti-abuse regulationsq adopted by the IRS. In addition, this book explores one of the fundamental questions that always arises in partnership taxation: Is a partnership to be treated as a separate taxable entity or an aggregate of its partners? The tension between entity and aggregate treatment of a partnership is one of the recurring issues in determining the tax consequences of partnership transactions. In addition to bringing the book up-to-date with the latest tax law changes and expansion of several chapters, the Third Edition contains new chapters on family partnerships, the death of a partner, and S corporations. It provides an extended discussion of allocation methods that do not have substantial economic effect, but are designed to be in accordance with the partners' interests in the partnership; series LLCs and their recently proposed regulations are also discussed in detail. The text is now suitable for both a qbasicq partnership tax course (if partnership tax can ever be thought of as basic), as well as an qadvancedq partnership tax course.The California Franchise Tax Board takes the position that each series in a Delaware series LLC is a separate entity for California ... Instructions to Form 568 , 2005 Limited Liability Company Tax Booklet. ... Comments on REG-119921-09 Proposed Regulations on Series of a Domestic Series Organization (Apr. 29, 2011).

Title:Partnership Taxation
Author:Richard Lipton, Paul Carman, Charles Fassler, Walter D. Schwidetzky
Publisher:LexisNexis - 2012-07-01


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