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The Logic of Subchapter K: A Conceptual Guide to the Taxation of Partnerships,9780314199850
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The Logic of Subchapter K: A Conceptual Guide to the Taxation of Partnerships

by ;
Edition:
4th
ISBN13:

9780314199850

ISBN10:
0314199853
Format:
Paperback
Pub. Date:
12/21/2010
Publisher(s):
West Academic
List Price: $86.00

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Summary

This product is designed to guide students through the conceptual framework of subchapter K. The material avoids neither the hard questions nor the conceptual difficulties, leaving students with a firm understanding of partnership taxation. Each chapter begins with a basic explanation of the relevant provisions and the roles that they play in the overall structure of subchapter K. It includes an increasingly detailed discussion of the specific rules, including multiple illustrative examples. Each chapter builds on the earlier chapters, leading the student through subchapter K. It is appropriate for J.D. or graduate-level law school courses on partnership taxation.

Table of Contents

Acknowledgementp. v
Table of Casesp. xiii
Table of Code Sectionsp. xv
Table of Revenue Rulingsp. xxiii
Table of Regulationsp. xxv
Choice of Entity: What is a Partnership for Tax Purposes?
Introductionp. 1
Definition of Partnershipp. 2
Choice of Form of Doing Businessp. 4
Electing Partnership Treatment: The "Check the Box" Regulationsp. 6
The Competing Concepts: Aggregate Versus Entityp. 7
Partnership Formation: The Basics
Introductionp. 9
Basic Statutory Schemep. 10
Common Issues on Formationp. 11
Property vs. Servicesp. 11
Contributions of Appreciated (or Depreciated) Propertyp. 11
Contribution of Depreciable Propertyp. 12
Characterization of Gains and Losses From the Disposition of Contributed Propertyp. 13
An Interim Examplep. 14
Liabilities-In Generalp. 15
Contribution of Encumbered Propertyp. 17
Contributions of Accounts Receivable and Payablep. 18
Organization and Syndication Expensesp. 19
Partnership Operations: The Basics
Introductionp. 21
Partnership Taxable Yearsp. 22
Method of Accountingp. 26
The Computation of A Partnership's Taxable Incomep. 26
In Generalp. 26
Separately Stated Itemsp. 27
Partnership Electionsp. 29
Adjustments to the Partners' Outside Basisp. 29
Financial Accounting and Maintenance of Capital Accounts
Introductionp. 32
Essential Elements of Financial Accountingp. 33
Basic Capital Accounting Rulesp. 34
Introduction to Tax Capital Accounts: Contributions and Revaluationsp. 38
Contributionsp. 39
Revaluationsp. 41
Partnership Allocations: Substantial Economic Effect
Backgroundp. 44
"Substantial Economic Effect"p. 45
The Significance of Capital Accounts: The Orrisch Casep. 47
Codification of Substantial Economic Effectp. 49
The 704(b) Regulationsp. 49
In General-Structurep. 49
Substantial Economic Effectp. 50
A Limitation-Family Partnershipsp. 71
Conclusionp. 73
The Allocation of Nonrecourse Deductions
Backgroundp. 74
Regulationsp. 78
Introductionp. 78
Definitionsp. 79
Illustrationsp. 83
Conclusionp. 88
Contributions of Property: Section 704(c) and Section 704(c) Principles
Introductionp. 90
Contributions of Propertyp. 92
Nondepreciable Propertyp. 92
Depreciable Propertyp. 99
Choice of Methodsp. 105
Anti-abuse Rulesp. 107
Revaluationsp. 109
Partnership Liabilities
Introductionp. 114
A Preliminary Issue: What is a Liability?p. 116
The Regulations Governing 1.752-1 Liabilitiesp. 118
Introductionp. 118
Economic Risk of Lossp. 118
Sharing Recourse Liabilitiesp. 119
Illustration-Recourse Liabilitiesp. 120
Partners Providing Property as Security for Partnership Debtp. 124
Sharing of Nonrecourse Liabilitiesp. 125
Transactions (Other than Sales) between a Partnership and its Partners
Sections 707(a) and 707(c)p. 129
Disguised Capital Expenditures: 707(a)(2)(A)p. 134
Receipt of Partnership Interest in Exchange for Servicesp. 138
A Final Note: Pending Legislationp. 142
The Sale of a Partnership Interest
Overviewp. 144
The Sellerp. 145
Statutory Schemep. 145
Section 751(a) Propertyp. 146
Section 751(a) Computationp. 148
Installment Sales of Partnership Interestsp. 151
The Buyerp. 152
Effect of the Adjustmentp. 161
Related Matters- 706(c) & (d)p. 163
Closing a Partnership's Taxable Yearp. 163
Allocation of Income for the Year of Changep. 164
Distributions-The Basics
Introductionp. 169
Preliminary Issuesp. 170
Sections 706(c) & (d)p. 170
Capital Accounting Rulesp. 171
Character and Holding Period of Distributed Propertyp. 171
Basis of Partnership's Undistributed Propertyp. 172
Recognition of Gain or Lossp. 172
Basis of Distributed Propertyp. 174
Current Distributionsp. 175
Liquidating Distributionsp. 178
Special Rule under 732(d)p. 184
Partnership Terminationp. 186
Optional Basis Adjustment- 734(b)
Introductionp. 188
Determination of the Amount of the Adjustment-Section 734(b)p. 189
Allocating the Adjustment Among Partnership Assets-Section 755p. 190
Examplesp. 191
Final Thoughtsp. 197
Disproportionate Distributions
Introductionp. 200
Section 751(b): The "Evil" and The "Cure"p. 201
The "Evil"p. 202
The "Cure"- 751(b)p. 202
Scopep. 206
Additional Examplesp. 207
Final Observationp. 215
Retirement and Death of a Partner
Retirements-Overviewp. 217
Section 736(b)-Deferred Liquidation Paymentsp. 218
Section 736(a) Paymentsp. 220
The Relationship between 736 and 751(b)p. 224
Death of a Partnerp. 224
Disguised Sales and Exchanges
Backgroundp. 228
Disguised Sales of Propertyp. 230
The Regulations Under 707(a)(2)(B)p. 230
Two-Year Presumptionsp. 231
Normal Distributionsp. 232
Examplesp. 233
Liabilitiesp. 235
Sections 704(c)(1)(B) and 737p. 242
Section 704(c)(1)(B)p. 243
Section 737p. 245
Disguised Sales of Partnership Interestsp. 247
The Partnership Anti-Abuse Rules
Backgroundp. 248
The General Anti-Abuse Rulep. 249
Intent of Subchapter Kp. 250
Facts and Circumstancesp. 250
Scopep. 251
Examplesp. 252
Abuse of Entity Rulep. 256
Is the Anti-Abuse Regulation Valid or Necessary?p. 257
Indexp. 261
Table of Contents provided by Ingram. All Rights Reserved.


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