Current developments in partners and partnerships
This article discusses developments in the taxation of partnerships and partners, debt and income allocations, distributions, and basis adjustments.
Basis
Accounting treatment for partnership syndication costs
This item discusses the tax basis and partnership capital accounting impacts of partner-incurred syndication costs.
Publicly traded partnerships: Tax treatment of investors
This article explains the tax implications of owning and selling an interest in a publicly traded partnership treated as a partnership and the tax reporting and compliance challenges that an investor in a PTP may face.
Current developments in partners and partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships and discusses developments in partnership formation, debt and income allocations, distributions, and basis adjustments.
The function of basis
A partner’s basis is key to determining the application of loss limitations and the recognition of gain or loss on partnership distributions and dispositions of partnership interests.
Current developments in partners and partnerships
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
Proposed regulations would allow Sec. 754 election without partner’s signature
To ease the regulatory burden on partnerships, the IRS announced that it is eliminating the requirement that partnership elections under Sec. 754 be signed by a partner.
IRS permits partnership basis election without partner’s signature
To ease the regulatory burden on partnerships, the IRS announced that it is eliminating the requirement that partnership elections under Sec. 754 be signed by a partner.
Sec. 743(b) adjustment complications in multitier partnerships
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
Basis for “Bad Boys”
Including “bad boy” provisions in loan agreements is a common practice to protect the lender in the commercial real estate finance industry.
Advantages of an Optional Partnership Basis Adjustment
The optional basis adjustment election is an attempt to allow partners to correct certain discrepancies by affecting a transferee’s allocable basis in the underlying partnership assets.
Current Developments in Partners and Partnerships
This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.
Making a Valid Sec. 754 Election Following a Transfer of a Partnership Interest
It is not uncommon for a partnership to attempt to make a valid Sec. 754 election, only to find that it failed to satisfy regulatory requirements.
Identifying What Constitutes Partnership Liabilities and How They Affect the Basis of Partnership Assets
Only partnership debt that has an impact on the partnership's inside basis is a liability. All other debt is excluded from consideration.
The Limited Liability Company Basis Limitation
Under Sec. 704(d), a member's allocable share of loss from a limited liability company (LLC) taxed as a partnership is deductible only to the extent of the member's outside basis in his or her LLC interest at the end of the LLC year. In determining a member's outside basis at year end, adjustments for increases and decreases are made in a specific order according to Regs. Sec. 1.704-1(d)(2).
Partnership Basis Rules Proposed
The IRS issued proposed regulations providing guidance on the application of Sec. 704(c)(1)(C) added by the American Jobs Creation Act and the amendments to the mandatory basis adjustment rules of Sec. 743 in the AJCA.
Debt and Proving Basis in Flowthrough Entities
A taxpayer’s basis is often scrutinized by the IRS, particularly when basis is claimed based upon debts incurred by a flowthrough entity.
Sec. 754 and Ground Leases
A partnership making an optional Sec. 754 basis adjustment for land subject to a long-term ground lease is permitted to adjust the basis of the land but may not allocate the basis adjustment to buildings or other depreciable assets the lessee constructed.
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.
