Partnership Taxation


Book Description

The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. In this concise, tightly edited casebook, George K. Yin and Karen C. Burke emphasize core principles and policies to help students understand the overall structure and coherence of partnership taxation. The book’s organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses, by offering a “building-block” approach that progresses from basic to complex partnership transactions. By emphasizing the policy choices that lend structure and coherence to the law, Partnership Taxation facilitates an understanding of the overarching principles of partnership tax. Students learn the law from basic source material—the Code and regulations—as well as tightly edited cases and other guidance. Many problems, questions, and explanations supplement the presentation to guide students through the challenging material. New to the Fourth Edition: The Fourth Edition reflects developments through February 2020, including: Expanded discussion of choice-of-entity issues in light of significant changes introduced by the 2017 tax legislation, including the 21% corporate tax rate and the section 199A passthrough deduction Revised regulations concerning allocation of partnership liabilities, including disregarded bottom-dollar payment obligations The temporary expensing deduction under section 168(k), as well as new limitations on business interest deductions and excess business losses New section 1061 imposing a three-year capital gain holding period for service partners receiving partnership interests in certain investment partnerships The revised definition of a “substantial built-in loss” under section 743(b) and repeal of the technical termination rule under section 708 Professors and students will benefit from: Approach: This book emphasizes core principles and policies to help students understand the overall structure and coherence of partnership taxation. Organization: The organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses; “building-block” approach progresses from basic to complex partnership transactions. Depth: By providing in-depth coverage while avoiding unnecessary detail, the revised Fourth Edition facilitates mastery of the material and prepares students to think rigorously and creatively about the kinds of problems they will encounter as practitioners of tax and business law. Lenny faces are short character strings that describe emotions and make your text stand out.




Partnership Tax Practice Manual


Book Description




Practical Guide to Partnerships and LLCs


Book Description

Practical Guide to Partnerships and LLCs (3rd Edition), by Robert Ricketts and Larry Tunnell, discusses the complex issues involving partnership taxation with utmost clarity. It uses hundreds of illustrative examples, practice observations, helpful charts and insightful explanations to make even the most difficult concepts understandable. The book reflects the authors' penchant for communicating the pertinent facts in very direct language and creating a context for understanding the multifaceted issues and applying them to practice.




Partnership Taxation


Book Description

View or download the free 2016 Online Supplement for this product. 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 Teacher's Manual provides suggested syllabi for both courses.




Understanding Partnership and LLC Taxation


Book Description

Based on his treatise Tax Planning for Partners, Partnerships, and LLCs, the author offers a comprehensive analysis of one of the most complex and confusing areas of the Internal Revenue Code. Using examples and computational illustrations, this Understanding treatise is designed for ease of use by law students. In addition to clear, to-the-point explanations of law, Understanding Partnership and LLC Taxation includes practice and planning notes plus extensive citation to relevant cases, statutes, and regulations, thereby making it also an excellent quick reference for practitioners. Among the topics covered are the tax consequences of: Determining the business form to adopt; Allocating income or loss among partners or LLC members; Distributing property to a partner or LLC member; Using family partnerships and LLCs; and Selling or liquidating a partnership or LLC interest.




Taxation and Business Planning for Partnerships and Llcs


Book Description

This highly anticipated new casebook provides comprehensive examination of tax principles with a unique practice-oriented approach to help students become practice ready with skills that they have developed in a setting that reflects practice in the real world. Taxation and Business Planning for Partnerships and LLCs includes background information about non-tax topics, such as basic accounting and finance, concepts related to debt, and state-law entity transactions so that classroom discussion can assume students have a general understanding of basic non-tax concepts. This new casebook also includes a general review of basic tax concepts that come up through the course of studying partnership taxation along with rules of conduct for attorneys who practice before the IRS. This first edition is accompanied by a unique Client File, which includes memoranda, documents such as operating agreements and loan documents, and spreadsheets with financial information. Each memorandum corresponds to a chapter in the casebook, and students will analyze the relevant information and apply the law presented to analyze the problems and present advice in a manner that a lawyer would to such clients.




Advanced Tax Strategies for LLCs and Partnerships


Book Description

Are you ready to master the advanced concepts of partnership taxation? Provide your clients with valuable advice and tax planning strategies and gain a working knowledge of the Internal Revenue Code's sophisticated partnership tax rules and regulations. This book takes a deep dive into the complexities of partnership tax law. It includes step-by-step examples to help guide you through the complicated world of advanced partnership and LLC tax law. Some of the many concepts covered in this course include special allocations, liquidating and non-liquidation distributions, property basis calculations under various scenarios, and sales of a partnership interest.




Partnerships and LLCs


Book Description




Partnership Income Taxation


Book Description

This book provides the simplest possible introduction of partnership taxation to students and beginning practitioners trying to understand the taxation of partnerships. Partnership taxation is an intricate body of law with the result that any "simplified" description of its rules would be so misleading as to be useless. We have therefore tried to make the subject accessible not by paraphrasing the rules, but by including over one hundred and forty examples of the rules that are as straightforward as possible. The text and examples focus on simple partnerships and limited liability companies that hold few assets and engage in routine transactions. The text places the rules in context by pointing out the purposes of the statute and regulations and presenting background information about practical matters such as how partnerships maintain capital accounts and how nonrecourse financing works. Using many examples, it then shows the operation of the rules in everyday cases encountered by practitioners. This is not a reference book: many interesting and difficult issues have been ignored. Some matters, such as the application of § 736 to noncash distributions and the taxation of tiered partnerships, are not discussed at all. Most of the points that are addressed, however, are discussed at considerable length. Our goal is to give students and beginning practitioners background material and illustrations so that they can begin to understand and work with a statute that was drafted for (and by) experienced practitioners and so that they can be prepared to make sense of the current law and any future changes. Most chapters end with a section comparing the tax treatment of partners with that of the shareholders of S corporations. Many students encountering partnership taxation for the first time have already studied subchapter S. We expect that an examination of some of the basic differences between subchapters S and K should help those students understand both subjects.




Partnership Taxation


Book Description

Finally, a partnership tax study guide with questions and answers. Written by an acclaimed teacher at Northwestern University, the Exam Pro on Partnership Taxation is designed to help JD and LLM students from the first day of class through the final exam. It begins with over 50 short lectures on topics in partnership tax ranging from basic to advanced, illustrated by over 250 study problems, each with a complete explanation of the right (and wrong) answers. Several of these lectures focus on the basic accounting concepts that are essential to understanding partnership tax, to give students with no prior accounting background the tools they need to succeed in this subject. The book includes nine sample exams that, like the lectures, increase in difficulty from basic to advanced, labeled so that students can pick the exams that are right for them and the course they are taking. Full answers to each of the exam questions are provided, with cross-references to the lectures and the study questions. Robert R. Wootton is a Professor of Practice at Northwestern Pritzker School of Law who practiced in big law for 25 years and was the Tax Legislative Counsel of the U.S. Treasury Department. The students in Northwestern Pritzker's LLM Tax Program have named him its outstanding tax professor seven times.