Partnership Taxation

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  • Publish Date: 2012-08-17
  • Binding: Hardcover
  • Author: Richard Lipton;Paul Carman;Charles Fassler;Walter D. Schwidetzky

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Partnership Taxation is one of several releases from the LexisNexis Graduate Tax Series. This book contains a thorough discussion of the rules of partnership taxation - when a partnership exists, the tax treatment of contributions to a partnership, the basis of partnership assets and interests in a partnership, how income is allocated to the partners, the tax treatment of distributions, the consequences of partnership liabilities, partnership mergers, the retirement of a partner and dissolution of the partnership. There is also significant attention paid to the numerous anti-abuse rules that have been adopted by Congress and the IRS over the past several decades, including the disguised sale rules, the treatment of mixing-bowl transactions, the complex rules to prevent basis abuse, and the overriding partnership anti-abuse regulations adopted by the IRS. In addition, this book explores one of the fundamental questions that always arises in partnership taxation: Is a partnership to be treated as a separate taxable entity or an aggregate of its partners? The tension between entity and aggregate treatment of a partnership is one of the recurring issues in determining the tax consequences of partnership transactions. In addition to bringing the book up-to-date with the latest tax law changes and expansion of several chapters, the Third Edition contains new chapters on family partnerships, the death of a partner, and S corporations. It provides an extended discussion of allocation methods that do not have substantial economic effect, but are designed to be in accordance with the partners interests in the partnership; series LLCs and their recently proposed regulations are also discussed in detail. The text is now suitable for both a basic partnership tax course (if partnership tax can ever be thought of as basic), as well as an advanced partnership tax course. The Teachers Manual provides suggested syllabi for both courses.

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