A CCA memorandum addressed the allocation of partnership losses where certain partners had negative capital account balances.
Gains & Losses
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
Tax Court affirmed the IRS’s decision to recharacterize loss of a partnership disposition from ordinary to capital when the taxpayers failed to provide evidence of abandonment.
A preparer’s improper change of status of income from active to passive is costly for taxpayers.
Should the IRS consider recognizing a contributing partner’s economic risk of loss when the regulations are finalized?
Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
The Tax Court held that a taxpayer had not elected to group two activities together under the passive activity loss rules simply by treating both activities as nonpassive.
Property transfers between a partner and a partnership are considered to be a taxable sale of the property under certain circumstances.
This article discusses the tax treatment of worthless or abandoned stock and partnership interests.
The regulations would create an exception to the general nonrecognition rule for property contributions to a partnership in exchange for a partnership interest.
IRS Chief Counsel Advice interpreted whether Sec. 752 should be used to determine whether a partnership’s debt is recourse or nonrecourse for purposes of COD income rules.
A partnership distribution may consist of cash, property, or both. In addition, any reduction of a partner’s share of partnership liabilities is treated as an actual distribution of cash.
The IRS intends to issue regulations under Sec. 721(c) to ensure that a U.S. person recognizes gain either immediately or periodically when it transfers certain property to a partnership that has foreign partners related to the transferor.
James M. Greenwell received the award for his article on Sec. 704(c) Allocations.
Proposed Regulations Would Require Gain or Loss Recognition on Certain Installment Obligation Transfers
The IRS issued proposed regulations that would require transferors that transfer installment obligations for equity interests in corporations or partnerships in nonrecognition transactions in satisfaction of those obligations to recognize gain or loss.
The IRS issued proposed regulations relating to the nonrecognition of gain or loss on certain dispositions of an installment obligation.
This item summarizes the aspects of the net investment income tax that are most relevant to hedge fund investors and general partners.
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, income allocations, and basis adjustments
The lack of regulatory and published guidance has created uncertainty in applying Sec. 897 to determine the amount of gain attributable to a USRPI.
The health care acts, along with recently issued Treasury guidance on the applicability of the additional Medicare tax, may prompt partnerships to reevaluate the potential tax impact of the partnership's structure on their individual partners.