Partnership Taxation

ISBN-13: 9781524985806 / Angielski / Miękka / 2019 / 264 str.

Pace

Spis treści

• About the Author
• PART I PARTNERSHIP FORMATION
• Chapter 1 Selecting a Business Entity
• A. Sole Proprietorship
• B. General Partnership
• C. Limited Partnership
• D. Limited Liability Partnership
• E. Limited Liability Limited Partnership
• F. Limited Liability Company
• G. Corporation
• H. Tax Treatment of Business Entities under the Check-the-Box Regulations
• I. Qualified Joint Ventures between Married Persons
• J. Obtaining an Employer Identification Number (EIN)
• Chapter 2 Transfer of Property to a Partnership
• A. Nonrecognition of Gain or Loss
• B. Partner's Initial Tax Basis in Partnership Interest
• C. Partner's Holding Period in Partnership Interest
• D. Partnership's Initial Tax Basis in Partnership Assets
• E. Special Rules Relating to Character of Property Contributed
• F. Partnership's Holding Period in Partnership Assets
• G. A Partner's Capital Account
• H. Contribution of Depreciable Assets
• I. Exception to Nonrecognition: "Investment Companies"
• J. Partnership Formation Example
• Chapter 3 Transfer of Services to a Partnership
• A. Performing Services in Return for Property in General
• B. Performing Services in Return for an Interest
• in the Partnership
• 1 . Tax Treatment to the Partner
• 2 . Tax Treatment to the Partnership
• 3 . Examples
• C. Special Rule Relating to Substantially Nonvested Profits Interests Received by a Partner in Return for the Performance of Services
• Chapter 4 Other Partnership Formation Issues
• A. Taxable Year
• B. Method of Accounting
• C. Costs Related to Partnership Formation
• D. Electing Out of Subchapter K
• PART II PARTNERSHIP OPERATIONS
• Chapter 5 Ordinary Business Income and Loss, Separately Stated Items, and Adjustments to Outside Basis
• A. Pass-Through Nature of a Partnership
• B. Partnership Ordinary Business Income
• C. Separately Stated Items
• D. Nature of Partnership Reporting (IRS Form 1065)
• E. Adjustments to a Partner's Outside Basis Due to Partnership Operations (Excluding Liabilities)
• F. Example
• G. Adjustments to a Partner's Outside Basis Due to Partnership Liabilities
• H. Partnership Interest Created by Gift
• Chapter 6 Limitations on Partnership Losses Deductible by Partners
• A. Outside Basis Limitation
• B. At-Risk Loss Limitation
• C. Passive Loss Limitation
• Chapter 7 Guaranteed Payments and Other Nondistribution Transactions between Partners and the Partnership
• A. Guaranteed Payments
• B. Other Nondistribution Transactions between Partners and the Partnership
• Chapter 8 Allocations Attributable to Built-in Gain or Loss Property
• A. General Rule Relating to Allocation of Profits and Losses
• B. Regulatory Allocations Applicable to Pre-contribution Gain or Loss
• C. Example
• Chapter 9 Special Allocations, Substantial Economic Effect, and Nonrecourse Deductions
• A. General Rule Relating to Allocation of Profits and Losses
• B. Substantial Economic Effect
• C. Evolution of "Targeted" Allocations
• D. Nonrecourse Deductions
• PART III DISTRIBUTIONS FROM A PARTNERSHIP TO A PARTNER
• Chapter 10 Nonliquidating and Liquidating Distributions
• A. Nonliquidating Distributions
• B. Liquidating Distributions
• C. Death or Retirement of a Partner
• Chapter 11 Disproportionate Distributions, Disguised Sales, and Other Distribution Issues
• A. Disproportionate Distributions
• B. Disguised Sales
• C. Distributions of Contributed Property
• D. Optional Basis Adjustments to Partnership Assets (Section 754 Election)
• PART IV SALE OF A PARTNERSHIP INTEREST AND PARTNERSHIP TERMINATIONS
• Chapter 12 Sale of a Partnership Interest
• A. Gain or Loss Recognition
• B. Exception for "Hot" Assets
• C. Buyer's Initial Outside Basis
• D. Optional Basis Adjustment to Partnership Assets (Section 754 Election)
• Chapter 13 Partnership Terminations, Mergers, and Divisions
• A. Partnership Terminations in General
• B. Partnership Mergers
• C. Partnership Divisions
• PART V Miscellaneous Partnership Tax Topics
• Chapter 14 Miscellaneous Partnership Tax Topics
• A. Carried Interests
• B. Reportable Transactions and Material Advisors
• C. Anti-abuse Rules
• D. Qualified Business Income Deduction
• Index