Are you ready to master the advanced concepts of partnership taxation? Provide your clients with valuable advice and tax planning strategies and gain a working knowledge of the Internal Revenue Code's sophisticated partnership tax rules and regulations. This book takes a deep dive into the complexities of partnership tax law. It includes step-by-step examples to help guide you through the complicated world of advanced partnership and LLC tax law.
Some of the many concepts covered in this course include special allocations, liquidating and non-liquidation distributions, property basis calculations under various scenarios, and sales of a partnership interest.
Table of Contents
Chapter 1 1-1
Allocation of Partnership and LLC Income Under Section 704(b) 1-1
Economic effect: The general test 1-3
Deemed economic effect 1-12
Alternate test for economic effect 1-13
Substantiality 1-17
Denied allocations: Determining the partners’ or LLC members’ interests in the entity 1-22
Other issues 1-25
Allocation of deductions attributable to nonrecourse debt 1-30
Summary 1-35
Chapter 2 2-1
Allocations With Respect to Contributed Property: Section 704(c)(1)(A) 2-1
The traditional method 2-4
The traditional method with curative allocations 2-12
The remedial allocations method 2-15
Special rules 2-19
Summary 2-22
Chapter 3 3-1
Allocation of Partnership Recourse Liabilities Under Section 752 3-1
How liabilities affect partner tax consequences 3-2
Allocation of liabilities among the partners: In general 3-12
Allocation of recourse liabilities 3-15
Chapter 4 4-1
Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b) 4-1
Distinguishing between recourse and nonrecourse liabilities 4-2
Allocation of nonrecourse debts 4-7
Treatment of contingent liabilities 4-15
Chapter 5 5-1
Advanced Distribution Rules 5-1
Non-liquidating distributions generally 5-2
Distribution of multiple properties 5-7
Summary 5-18
Chapter 6 6-1
Adjustments to the Basis of Partnership or LLC Assets 6-1
Section 743: Adjustments following the transfer of a partnership interest 6-3
Distributions of partnership property 6-6
Allocating the adjustment amount among partnership properties 6-15
Chapter 7 7-1
Sale of an Interest in a Partnership or LLC 7-1
General tax consequences associated with sale 7-2
“Hot” assets and Section 751(a) 7-7
Collectibles and unrecaptured Section 1250 gain 7-12
Installment sales 7-14
Net investment income tax 7-16
Sale of an active (non-passive) interest in a partnership or LLC 7-17
Sale of a passive interest in a partnership or LLC 7-19
Purchaser of a partnership interest 7-20
Glossary Glossary 1
Index Index 1
Solutions Solutions 1
Chapter 1 Solutions 1
Chapter 2 Solutions 3
Chapter 3 Solutions 4
Chapter 4 Solutions 6
Chapter 5 Solutions 8
Chapter 6 Solutions 10
Chapter 7 Solutions 12
