Partner Transactions

Topics

January 6, 2022

What’s new for 2022 in federal taxes

A law change and some regulations take effect while an array of provisions expire.

October 1, 2021

Unvested partnership interests as compensation

This item focuses on the use of unvested capital
interests as compensation.

July 1, 2021

Partnership continuity in restructuring transactions

The issue of whether a partnership continues or terminates for U.S. federal income tax purposes frequently arises in restructuring transactions.

May 1, 2021

The partner-to-partner attribution trap and the anti-churning rules

Taxpayers dealing with tax basis step-up transactions involving related parties or rollover equity interests should consider the application of the anti-churning rules to avoid unforeseen results.

April 8, 2021

Sec. 1446(f) regulations: The rules and unanswered questions

This article addresses certain aspects of the withholding rules of the final Sec. 1446(f) regulations, options to eliminate or reduce Sec. 1446(f) withholding, and some outstanding issues.

June 1, 2020

Deduction limitations of Sec. 162(m) to compensation paid by partnerships in Up-C and UPREIT structures

Proposed regulations change the paradigm for the tax treatment of compensation paid by a partnership situated below a publicly held corporation in an Up-C or UPREIT structure.

June 1, 2020

Withholding and reporting of partnership distributions to non-US partners

The mechanics of the withholding regime seem straightforward, but they can be difficult for certain
tiered partnership structures.

May 1, 2020

Bottom-dollar payment obligations

In highly leveraged partnerships, bottom-dollar payment obligations have been used by partners to increase their at-risk basis in a partnership to use loss allocations or to receive nontaxable cash distributions.

September 1, 2017

Partner’s bonus was not a partnership distribution

A bonus payment to a hedge fund manager was payment for services outside her capacity as a partner.

May 1, 2017

Sec. 743(b) adjustment complications in multitier partnerships

Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.

July 1, 2016

Missing Partnership Merger Definition Raises Questions

Regulations governing the federal income tax consequences of a partnership merger lack clear guidance on when a transaction resulting in the combination of two partnerships into a single partnership constitutes a merger.

February 1, 2016

Current Developments in Partners and Partnerships

This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.

February 1, 2014

Current Developments in Partners and Partnerships

This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, income allocations, and basis adjustments

February 1, 2012