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Advanced Tax Strategies for LLCs and Partnerships

Advanced Tax Strategies for LLCs and Partnerships

Larry Tunnell, Robert Ricketts

ISBN: 978-1-119-51238-7

Mar 2018

224 pages

$75.99

Chapter 1 1-1

Allocation of Partnership and LLC Income Under Section 704(b) 1-1

Economic Effect: The General Test 1-3

Deemed Economic Effect 1-13

Alternate Test for Economic Effect 1-14

Substantiality 1-18

Denied Allocations: Deter 1-23

Other Issues 1-26

Allocation of Deductions Attributable to Nonrecourse Debt 1-31

Summary 1-35

Chapter 2 2-1

Allocations With Respect to Contributed Property: Section 704(c)(1)(A) 2-1

The Traditional Method 2-4

The Traditional Method With Curative Allocations 2-13

The Remedial Allocations Method 2-16

Special Rules 2-21

Summary 2-24

Chapter 3 3-1

Allocation of Partnership Recourse Liabilities Under Section 752 3-1

How Liabilities Affect Partner Tax Consequences 3-2

Determining the Partners’ or LLC Members’ Interests in the Entity..Allocation of Liabilities Among the Partners: In General 3-12

Allocation of Recourse Liabilities 3-15

Chapter 4 4-1

Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b) 4 -1

Distinguishing Between Recourse and Nonrecourse Liabilities 4-2

Allocation of Nonrecourse Debts 4-7

Treatment of Contingent Liabilities 4-16

Chapter 5 5-1

Advanced Distribution Rules 5-1

Non-Liquidating Distributions Generally 5-2

Distribution of Multiple Properties 5-7

Summary 5-20

Chapter 6 6-1

Adjustments to the Basis of Partnership or LLC Assets 6-1

Section 743: Adjustments Following the Transfer of a Partnership Interest 6-3

Distributions of Partnership Property 6-6

Allocating the Adjustment Amount Among Partnership Properties 6-16

Chapter 7 7-1

Sale of an Interest in a Partnership or LLC 7-1

General Tax Consequences Associated With Sale 7-2

“Hot” Assets and Section 751 7-6

Collectibles and Unrecaptured Section 1250 Gain 7-11

Installment Sales 7-13

Net Investment Income Tax 7-15

Sale of an Active (Non-passive) Interest in a Partnership or LLC 7-16

Sale of a Passive Interest in a Partnership or LLC 7-18

Potential for Termination of the Partnership 7-19

Consequences to the Purchaser 7-25

Tax Glossary Tax Glossary 1

Index Index 1