The mechanics of the withholding regime seem straightforward, but they can be difficult for certain tiered partnership structures.
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
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.
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, income allocations, and basis adjustments
This article reviews and analyzes recent rulings and decisions involving partnerships.