Partnership Income Taxation

, by Gunn, Alan

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ISBN: 9781566627993 | 1566627990
Cover: Paperback
Copyright: 9/1/1999

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Preface

The Pass-Through Principle of Partnership Taxation

(12)

Introduction

(2)

Illustration

(2)

The Tax Basis of Partnership Interests and Partnership Property

(2)

The Timing of Partnership Income

(1)

The Duration of A Partnership

(1)

Partners As Self-Employed Taxpayers

(1)

The ``Anti-Abuse'' Regulations

(2)

Comparison with Sub S

(1)

An Introduction to Partnership Debt

(18)

The Effects of Debt Transactions upon Partners

(2)

Determining the Partners' Shares of Partnership Debt

(9)

Some Aspects of Debt

(2)

What Is A Partnership Debt?

(1)

Determining A Partner's Share of Debt under the Regulations

(1)

Nonrecourse Debt

(3)

Recourse Debt

(2)

``Anti-Abuse rules'' and the Allocation of Debt

(1)

Limits On the Deductibility of Partnership Losses

(5)

Section 704(D)

(1)

The At-Risk Rules of Section 465

(1)

The Passive-Loss Rules of Section 469

(2)

Comparison with Subchapters

(2)

Contributions to Partnerships

(24)

Contributions of Property

(7)

The Statutory Pattern

(1)

Problems Involving Liabilities

(4)

Depreciation Recapture

(1)

Character Issues: Section 724

(1)

Contributions of Services

(9)

Receipt of an Interest in Partnership Capital

(3)

Receipt of an Interest in Partnership Profits

(5)

Contributions Distinguished From Other Transactions

(5)

Contribution vs. Sale to Partnership

(3)

Contribution vs. Sale or Exchange between Partners

(1)

Comparison with Subs

(3)

Allocations of Partnership Income, Deductions, and Credits: An Introduction

(38)

An Overview of the Code and Regulations

(1)

The ``Substantial Economic Effect'' Test

(20)

Introduction

(1)

Capital Accounts

(4)

The ``Substantial Economic Effect'' Regulations

(1)

Determining ``Economic Effect'' When Capital-Account Deficits Need Not Be Repaid

(3)

The ``Substantiality'' Rules

(4)

Some Special Problems

(1)

Depreciation

(3)

Deductions Attributable to Nonrecourse Debt

(4)

Contributed Property: Section 704(C)

(16)

Allocations of Gain or Loss

(4)

Allocations of Depreciation

(1)

The Traditional Method

(2)

The Traditional Method with Curative Allocations

(3)

The Traditional Method with Remedial Allocations

(3)

``Reverse § 704(c) Allocations'' under Section 704(b)

(1)

Distributions of Section 704(c) Property

(1)

Distributions of Property to a Partner Who Has Contributed Section 704(c) Assets

(2)

Allocating Credits

(1)

Comparison with Subs

(1)

Partnership Allocations: Assignment-of Income Problems

(8)

Family Partnerships

(3)

Last-Minute Partners: Section 706(D)

(1)

Assignments of Income Not Dealt With By Specific Code Provisions: the Anti-Abuse Regulations

(4)

Comparison with Subs

100

(1)

Transactions between Partnerships and Their Partners

101

(12)

Income-Related Payments: Distributive Shares and Section 707(a) Payments

103

(3)

Fixed Payments: Guaranteed Payments and Section 707(a) Payments

106

(1)

Determining Whether A ``Partner Capacity'' Payment Is A Distributive Share or a Guaranteed Payment

107

(3)

Minimum Payments

107

(3)

Payments Measured by a Partnership's Gross Income

110

(1)

Some Other Aspects of Transactions Between Partners And Partnerships

110

(1)

Comparison with Subchapters

111

(2)

Sales of Partnership Interests

113

(20)

Taxation of the Seller

113

(6)

The Seller's Amount Realized

113

(1)

Section 751 (a)

114

(5)

The Buyer's outside and Inside Bases

119

(10)

The Buyer's Outside Basis

119

(1)

Inside Basis Adjustments under Section 743(b)

119

(1)

Determining the Transferee's Share of Inside Basis

120

(2)

Allocating § 743(b) Adjustments to Particular Assets

122

(4)

Using the § 743(b) Adjustment

126

(1)

The Section 754 Election

127

(1)

Basis Adjustments under Section 732(d)

128

(1)

Collateral Effects of A Sale of A Partnership Interest

129

(2)

Comparison with Subs

131

(2)

Calculating Gain on the Sale of Stock

131

(1)

Character of Gain and Inside Basis Adjustments upon Transfers of Interests

131

(1)

Termination by Sale

132

(1)

Partnership Distributions: an Introduction

133

(16)

The General Principle of Nonrecognition

134

(5)

Cases in Which Gain or Loss is Recognized

139

(6)

Gain Recognition

139

(2)

Liquidating Distributions on Which Loss Is Recognized

141

(1)

``De Minimis'' Distributions of Property

142

(1)

Distributions of Section 704(c) Property

143

(1)

Distributions Taxed under Section 737

144

(1)

Distributions and the Anti-Abuse Regulations

145

(1)

Tax Treatment of the Partnership

146

(1)

Comparison with Subchapters

146

(3)

Distributions Subject to Section 751(b)

149

(16)

Liquidating Distributions of Assets Other Than Section 751 Assets

152

(4)

Liquidating Distributions of Section 751 Property

156

(3)

Section 751 (a) and Current Distributions

159

(2)

The Scope of Section 751 (a): An Example

161

(2)

Comparison with Subchapters

163

(2)

Payments to Retiring Partners: Section 736 and Related Problems

165

(16)

Introduction

165

(4)

Payments ``for Property'' and Other Payments

167

(1)

Payments by Service Partnerships to General Partners

167

(2)

How Section 736 Payments Are Taxed

169

(2)

Examples

171

(2)

Some Complications

173

(3)

The Relationship between Section 736 and Section 751 (b)

173

(2)

A Refinement in the Definition of Section 736(a) Payments

175

(1)

Liquidation of an Entire Partnership

175

(1)

Sales and Retirement Payments Distinguished

176

(3)

Problems of ``Form'' and ``Substance''

179

(1)

Comparison with Subchapters

180

(1)

Basis Adjustments under Section 734

181

(10)

Adjustments Under Section 734

182

(5)

Distributions That Change the Basis of Property

182

(1)

Distributions on Which Gain or Loss Is Recognized

183

(3)

Allocating the Adjustment to Particular Asset

186

(1)

Section 734 and the Anti-Abuse Regulations

187

(2)

Comparison with Subchapters

189

(2)

The Death of a Partner

191

(8)

Income in Respect of a Deceased Partner

191

(5)

Introduction

191

(1)

The Basis of an Inherited Partnership Interest

192

(4)

Closing the Partnership's Taxable Year upon the Death of a Partner

196

(1)

Sale or Liquidation of a Deceased Partner's Interest

197

(1)

Comparison with Subchapters

197

(2)

What Is a Partnership?

199

(12)

Partnership vs. Cost-Sharing and Employment Arrangements

200

(1)

Partnership vs. Co-Ownership Of Property

201

(3)

Partnership vs. Corporation

204

(3)

Publicly Traded Partnerships

207

(1)

Electing Large Partnerships

208

(3)

Table of Cases

211

(2)

Table of Internal Revenue Code Sections

213

(2)

Table of Treasury Regulations and Rulings

215

(2)

Index

217

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Partnership Income Taxation

Table of Contents

Supplemental Materials