U.S. Taxation of Partnerships: Advanced Topics
U.S. Taxation of Partnerships: Advanced Topics

Author: Felix Lessambo

Publisher: Kluwer Law International B.V.

Published: 2021-05-21

Total Pages: 146

ISBN-13: 9403533846

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As the number of businesses registered as partnerships continues to grow in the United States (U.S.)—there are now more than seven million—it is imperative for parties with business interests in the country to be fully informed of the challenges pertaining to this sui generis form of business and its intricate body of tax law. In an illustrative manner not covered by other books on the subject, this invaluable guide discusses, analyzes, dissects, and helps resolve issues arising in such contexts as accounting methods, anti-abuse rules, liabilities, dissolutions, mergers, and bankruptcy, with expert guidance on preparing partnership financial statements. With numerous boxed examples and references to important court cases, the author thoroughly describes such topics as the following: types of partnerships (LP, LLP, LLC, PTP); the two concepts of partnerships; partnership formation; transactions between partnership and partners; allocation of revenues among partners; the partnership taxable year; base erosion and anti-abuse tax (BEAT); centralized partnership audit regime; recourse and nonrecourse liabilities; and special tax rules for publicly traded partnerships (PTPs). Key abstract concepts are explained in a down-to-earth way, and all formal requirements—filing the partnership tax return (Form 1065), reporting, preparing for an audit, and so on—are clearly illustrated with examples. As the first book to describe the economics of partnerships in a concise and comprehensive manner, this book provides a reliable and authoritative overview of the complexities of U.S. partnership taxation and expounds the relevant rules in accessible language. It will be warmly welcomed by tax law practitioners, members of international and U.S. tax law associations, tax academics, and the international business communities with interests in the U.S.

Federal Income Taxation of Partners and Partnerships in a Nutshell
Federal Income Taxation of Partners and Partnerships in a Nutshell

Author: Karen C. Burke

Publisher: West Publishing Company

Published: 1999

Total Pages: 0

ISBN-13: 9780314230461

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Common Law and Equitable Remedies for Breach of Contract; Expectation Damages; Restitution; Reliance Damages; Specific Performance; Contracts for the Sale of Goods: Buyers' and Sellers' Remedies Under Article II of the UCC; Remedies Available to Buyer When He Has Not Accepted the Goods; Remedies Available to Buyer After He Has Accepted the Goods, Including Remedies for Breach of Warranty; Remedies Available to Seller When Buyer Defaults and Has Not Accepted the Goods; Remedies Available to Seller After Buyer has Accepted the Goods; Contractual Control Over Remedy; Liquidated Damages Clauses; Contractual Modification or Limitation of Remedy Under UCC 2-719; Remedies for Mistake and Unconscionability; Mistake in the Formation of an Agreement -- The Recission and Restitution Remedies; Mistake in Integration or Expression The Reformation Remedy: Mistake in Performance of an Obligation The Restitution Remedy; Unconscionability.

Federal Income Taxation of Partners and Partnerships in a Nutshell
Federal Income Taxation of Partners and Partnerships in a Nutshell

Author: Karen C. Burke

Publisher:

Published: 2020

Total Pages:

ISBN-13: 9781684678297

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"This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised sixth edition reflects major tax legislation enacted in 2017 (the "2017 Act"), including choice of entity issues in light of the new 21% corporate tax rate and the § 199A passthrough deduction."--Publisher website.

Partnership Taxation
Partnership Taxation

Author: George K. Yin

Publisher: Aspen Publishing

Published: 2020-09-15

Total Pages: 464

ISBN-13: 1543827276

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The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. In this concise, tightly edited casebook, George K. Yin and Karen C. Burke emphasize core principles and policies to help students understand the overall structure and coherence of partnership taxation. The book’s organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses, by offering a “building-block” approach that progresses from basic to complex partnership transactions. By emphasizing the policy choices that lend structure and coherence to the law, Partnership Taxation facilitates an understanding of the overarching principles of partnership tax. Students learn the law from basic source material—the Code and regulations—as well as tightly edited cases and other guidance. Many problems, questions, and explanations supplement the presentation to guide students through the challenging material. New to the Fourth Edition: The Fourth Edition reflects developments through February 2020, including: Expanded discussion of choice-of-entity issues in light of significant changes introduced by the 2017 tax legislation, including the 21% corporate tax rate and the section 199A passthrough deduction Revised regulations concerning allocation of partnership liabilities, including disregarded bottom-dollar payment obligations The temporary expensing deduction under section 168(k), as well as new limitations on business interest deductions and excess business losses New section 1061 imposing a three-year capital gain holding period for service partners receiving partnership interests in certain investment partnerships The revised definition of a “substantial built-in loss” under section 743(b) and repeal of the technical termination rule under section 708 Professors and students will benefit from: Approach: This book emphasizes core principles and policies to help students understand the overall structure and coherence of partnership taxation. Organization: The organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses; “building-block” approach progresses from basic to complex partnership transactions. Depth: By providing in-depth coverage while avoiding unnecessary detail, the revised Fourth Edition facilitates mastery of the material and prepares students to think rigorously and creatively about the kinds of problems they will encounter as practitioners of tax and business law. Lenny faces are short character strings that describe emotions and make your text stand out.

Partnership Taxation
Partnership Taxation

Author: Robert R. Wootton

Publisher:

Published: 2016

Total Pages: 563

ISBN-13: 9781684678945

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The Second Edition of the Exam Pro on Partnership Taxation extends the approach of the original as a partnership tax study guide with questions and answers . Completely revised and updated, it includes lectures and study questions on the deduction for qualified business income under section 199A, the new regulations on allocating partnership recourse debt, and the choice of entity for conducting business and investment activities. New sample exams at the basic, intermediate and advanced levels give you an even better shot to ace your partnership tax exam. The book is designed to help JD and LLM students from the first day of class. It begins with over 50 short lectures on topics in partnership tax ranging from basic to advanced, illustrated by over 280 study questions, each with a complete explanation of the right (and wrong) answers. Several of the lectures focus on the basic accounting concepts that are essential to understanding partnership tax, to give students with no prior accounting background the tools they need to succeed in this subject. The book includes twelve sample exams (a total of 120 more questions) that, like the lectures, increase in difficulty from basic to advanced, labeled so that students can pick the exams that are right for them and the cours(more...)

Advanced Tax Strategies for LLCs and Partnerships
Advanced Tax Strategies for LLCs and Partnerships

Author: Larry Tunnell

Publisher: John Wiley & Sons

Published: 2020-08-04

Total Pages: 208

ISBN-13: 1119748739

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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.

Partnership Taxation
Partnership Taxation

Author: Richard M. Lipton

Publisher:

Published: 2012

Total Pages: 0

ISBN-13: 9780769849034

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View or download the free 2016 Online Supplement for this product. Partnership Taxation is one of several releases from the LexisNexis Graduate Tax Series. This book contains a thorough discussion of the rules of partnership taxation -- when a partnership exists, the tax treatment of contributions to a partnership, the basis of partnership assets and interests in a partnership, how income is allocated to the partners, the tax treatment of distributions, the consequences of partnership liabilities, partnership mergers, the retirement of a partner and dissolution of the partnership. There is also significant attention paid to the numerous "anti-abuse" rules that have been adopted by Congress and the IRS over the past several decades, including the disguised sale rules, the treatment of "mixing-bowl" transactions, the complex rules to prevent basis abuse, and the overriding "partnership anti-abuse regulations" adopted by the IRS. In addition, this book explores one of the fundamental questions that always arises in partnership taxation: Is a partnership to be treated as a separate taxable entity or an aggregate of its partners? The tension between entity and aggregate treatment of a partnership is one of the recurring issues in determining the tax consequences of partnership transactions. In addition to bringing the book up-to-date with the latest tax law changes and expansion of several chapters, the Third Edition contains new chapters on family partnerships, the death of a partner, and S corporations. It provides an extended discussion of allocation methods that do not have substantial economic effect, but are designed to be in accordance with the partners' interests in the partnership; series LLCs and their recently proposed regulations are also discussed in detail. The text is now suitable for both a "basic" partnership tax course (if partnership tax can ever be thought of as basic), as well as an "advanced" partnership tax course. The Teacher's Manual provides suggested syllabi for both courses.

Partnership Taxation
Partnership Taxation

Author: Robert R. Wootton

Publisher:

Published: 2016

Total Pages: 0

ISBN-13: 9781634594943

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Finally, a partnership tax study guide with questions and answers. Written by an acclaimed teacher at Northwestern University, the Exam Pro on Partnership Taxation is designed to help JD and LLM students from the first day of class through the final exam. It begins with over 50 short lectures on topics in partnership tax ranging from basic to advanced, illustrated by over 250 study problems, each with a complete explanation of the right (and wrong) answers. Several of these lectures focus on the basic accounting concepts that are essential to understanding partnership tax, to give students with no prior accounting background the tools they need to succeed in this subject. The book includes nine sample exams that, like the lectures, increase in difficulty from basic to advanced, labeled so that students can pick the exams that are right for them and the course they are taking. Full answers to each of the exam questions are provided, with cross-references to the lectures and the study questions. Robert R. Wootton is a Professor of Practice at Northwestern Pritzker School of Law who practiced in big law for 25 years and was the Tax Legislative Counsel of the U.S. Treasury Department. The students in Northwestern Pritzker's LLM Tax Program have named him its outstanding tax professor seven times.

Partnership Income Tax (Form 1065)
Partnership Income Tax (Form 1065)

Author: Brian Smith

Publisher: THE PUBLISHER

Published: 2024-03-08

Total Pages: 85

ISBN-13:

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This book provides a comprehensive guide to understanding and navigating the complexities of Partnership Income Tax (Form 1065) for businesses. Covering various chapters, it begins by explaining the purpose and filing requirements of Form 1065, along with the associated deadlines and penalties. It then delves into partnership information, including identification details, business activity specifics, and partner information. The book further explores income, deductions, and tax credits for partnerships, detailing the various income categories, allowable deductions, and tax credits available. It also covers the allocations within a partnership, the preparation of Schedule K-1, and the distribution of income, deductions, and credits among partners. Understanding and reporting partners' capital accounts is the focus of another chapter, which includes the calculation of capital contributions, withdrawals, adjustments, and reporting specifics. The book also addresses special reporting issues such as foreign partnerships, publicly traded partnerships, and tax-exempt organizations as partners. Other important topics covered include tax payments, withholdings, required schedules and attachments, amending Form 1065, IRS audits and examinations, tax planning strategies for partnerships, state and local tax considerations, partnership termination and liquidation, and relevant IRS forms and publications. Throughout the book, the authors highlight common mistakes and provide tips to avoid them, ensuring accurate reporting and minimizing audit risks. Overall, this guide offers a comprehensive resource for partnership businesses to confidently navigate the intricacies of Partnership Income Tax (Form 1065). Disclaimer: I am not a licensed attorney or accountant, and the information provided in this book, "Partnership Income Tax (Form 1065)," is for educational and informational purposes only. The content contained herein is not intended to be, nor should be construed as, legal or financial advice. Readers are encouraged to seek the expertise of qualified professionals, such as certified public accountants (CPAs) or tax attorneys, to address their specific legal or financial concerns. The author does not assume any responsibility for errors, inaccuracies, or omissions in the information provided or for any actions taken in reliance on this information. Tax laws and regulations are subject to change, and the application of tax laws can vary based on individual circumstances. It is strongly recommended that readers consult with a qualified professional to obtain advice tailored to their specific situation. By reading this book, the reader acknowledges and agrees that the author is not liable for any loss, damage, or inconvenience arising from the use of or reliance upon the information contained herein, and the reader takes full responsibility for their decisions and actions based on the content of this book. This disclaimer is a general statement and may need to be customized based on the specific content and context of your book. It is always advisable to seek legal advice to ensure your disclaimer is appropriate for your particular circumstances.