Real estate partnership restructuring and potential disguised sales
With certain restructuring transactions, careful consideration is needed to prevent the transaction from being deemed a disguised sale.
Partner Transactions
Regulations streamline partnership basis elections
Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
Payments to LLC members for services
When LLC members receive payments for services performed for the LLC, the tax treatment depends on whether the member is performing the services in the capacity as a member.
State tax considerations around the sale of a partnership interest
This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.
Deferred compensation not deductible in year basketball franchise sold
No deduction is allowed in the year of sale of a basketball team for deferred compensation owed to two of the team’s players.
What’s new for 2022 in federal taxes
A law change and some regulations take effect while an array of provisions expire.
Unvested partnership interests as compensation
This item focuses on the use of unvested capital interests as compensation.
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.
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.
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.
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.
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.
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.
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.
Sec. 743(b) adjustment complications in multitier partnerships
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
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.
Current Developments in Partners and Partnerships
This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.
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
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships.
