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Browse Partnership distributions topic

Taxation subtopic


1-50 out of 50 article(s)
Title Author Type Date Words
Tax Treatment of Liquidations of Partnership Interests. Smith, Eric Column Dec 1, 2020 1367
Father's treatment of partnership interest expense does not bind son: The son, who inherited and received as gifts the interests in real estate partnerships, could treat nonrecourse debt as acquisition indebtedness, the Tax Court holds. Meade, Janet A. Dec 1, 2019 882
Publicly traded partnerships: Tax treatment of investors. Drnevich, Dawn; Sternburg, Thomas Apr 1, 2019 6443
Attorneys are not limited partners: PLLC member-managers are held to not be entitled to a self-employment income exclusion of distributive shares. Aquilio, Mark Jul 1, 2017 785
Recognizing when a disguised sale of property takes place. Ellentuck, Albert B. Aug 1, 2016 954
Liquidation of an LLC. Ellentuck, Albert B. Jun 1, 2016 2750
Sec. 304 and rev. rul. 99-6: fitting a triangular peg in a round hole. Bodoh, Devon M.; Featherman, Greg W.; Simmons, Andrew D. Jun 1, 2016 1969
Gifts of partnership interests: a donor must be wary of the tax consequences of a gift of a partnership interest, especially if the donor has a negative basis in the partnership interest. Ellentuck, Albert B. Apr 1, 2016 915
Identifying a partnership distribution. Ellentuck, Albert B. Oct 1, 2015 866
IRS prohibits corporations from circumventing gain on appreciated property using partnerships. Schreiber, Sally P. Sep 1, 2015 900
Accounting for the death of a partner: a partner's death raises several tax issues that practitioners should be aware of when doing pre- and postmortem planning for partners and partnerships. Ellentuck, Albert B. Aug 1, 2015 3112
Basis adjustments in CFC stock held by partnerships for subpart F inclusions, PTI distributions. Yu, Hui Jul 1, 2015 1233
The new revolution in partnership tax? Monroe, Andrea Sep 22, 2013 20781
Application of sec. 704(c) to divisions. Schmalz, John; Krause, Arielle; Arndt, Matthew Jul 1, 2013 1186
Payments to taxpayer held to be compensation, not distributions. Beavers, James A. Feb 1, 2013 1135
The partnership "technical termination" trap. Blikshteyn, Vadim; Reminick, Holtz Rubenstein Oct 1, 2012 1531
LLC distributions of contributed property. Ellentuck, Albert B. Oct 1, 2012 2116
IRS wins again on annual exclusion of gifts of partnership interests. Johnson, Eric L.; Janes, Craig L. Mar 1, 2011 4365
The tax cost of hot assets upon the disposition of a partnership interest. Bakale, Anthony S. Aug 1, 2010 1706
Trusts owning partnership interests and the revised UPIA. Cantrell, Carol A.; Spoor, Gordon Jan 1, 2010 1179
When to report ordinary income if a partnership with hot assets redeems a partnership interest and the liquidating distributions are made over several tax years. Bensimon, Daniel Oct 1, 2009 4133
Trusts owning partnership interests. Bazley, Thomas E.; Hills, Marvin D. Sep 1, 2009 2544
Like-kind exchanges of partnership properties. Smith, Michael M.; Ariail, Donald L. Dec 1, 2008 2998
Special issues related to distributions of partnership interests by estates and trusts. Bottiglieri, Tom Feb 1, 2008 1043
Planning for current distributions from an LLC. Ellentuck, Albert B. Feb 1, 2008 1900
Partner loans: traps for the unwary. Foley, Gretchen Jul 1, 2006 1208
Is disputed partnership income taxable? Reichert, Charles J. May 1, 2006 519
Tax effects on partnership and limited liability company interests: using section 754 elections to enhance value and marketability. Streer, Paul J.; Strobel, Caroline D. Feb 1, 2005 3254
Avoiding tax on liquidating distributions of partnership property through timing of distributions. Ellentuck, Albert B. Oct 1, 2003 838
Divided holding periods for partnership interests. Packard, Pamela May 1, 2001 909
New partnership basis rules. Bakale, Anthony Aug 1, 2000 2497
Prop. regs. on allocation of partnership debt. Bakale, Anthony Aug 1, 2000 1059
Tax-deferred disposition of a former partnership business via a type b stock swap. Ellentuck, Albert B. Aug 1, 2000 1070
Applying the rules governing distributions of marketable securities. Ellentuck, Albert B. Jun 1, 2000 1194
Allocation of basis among properties distributed by partnerships. Keller, Brian E. Sep 1, 1998 1409
The TRA '97's new basis allocation rules for property distributions. Streer, Paul J. Jul 1, 1998 5724
Distributions by LLCs. Mangina, Norman J.; Plummer, Elizabeth; Streer, Paul J. Apr 1, 1997 3434
Proposed regulations eliminate deemed distributions on technical termination of partnerships. Ingram, Valorie L. Sep 1, 1996 663
Final rules on distributions of partnership property. Schmalz, John G. Apr 1, 1996 956
Distributions of marketable securities from partnerships. Gorrin, Eugene Apr 1, 1996 4073
Recent developments. Nellen, Annette Mar 1, 1996 5700
Continuity-of-interest requirement not affected by partnership's distribution of stock received in reorganization. Wang, C.Y. Brief Article Jan 1, 1996 396
Distributive share of foreign partnership income held subpart F income. Josephs, Stuart R. Brief Article May 1, 1995 108
Withholding for foreign partners. Basile, John Apr 1, 1995 1789
Small business tax solutions. Sayre, Julian R. Apr 1, 1995 804
Basis adjustments for liquidation payments to retiring and deceased partners. Harris, Richard W. Jul 1, 1994 3532
New regulations on built-in gains and losses on property contributed to a partnership. Zinneman, David E.; Bolling, Rodger A. Cover Story Mar 1, 1994 5872
Allocation of income without substantial economic effect - what's going on here? Levinton, Howard Feb 1, 1994 614
Disguised sale final regulations. O'Neil, Paul A. Nov 1, 1993 1040
Partnership must delay sec. 734(b) adjustments until retiring partner recognizes gain or loss. Savage, Richard Brief Article Jun 1, 1993 468

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