Part I concludes with a brief discussion of the general anti-abuse regulations. Distribution to Contributing Partner - Section 737 C. Part II discusses the principles applicable to all distributions — current and liquidating — including distinguishing between them — and the general principles for nonrecognition of gain or loss on distributions of partnership property in kind, and the effect of partnership liability shifts as part of distributions.
Worksheet 7 Omnibus Budget Reconciliation Act of 1993 Conference Report Section 13206(e) - Definition of “Substantially Appreciated” Inventory (P. Worksheet 7B Taxpayer Relief Act of 1997 Worksheet 8 ABCD Partnership Agreement (Liquidation Article).
Worksheet 7A General Agreement on Tariffs and Trade, Section 741 of the Revenue Provisions (Title VII), Relating to Partnership Distributions (Act Language and Technical Explanation) (1994).
Insurance Payable to Partnership (Funded Buy-Out) 4.
Judicially Created IRD Working Papers Table of Worksheets Worksheet 1 Excerpts from House Ways and Means Committee Report to H.
Part III deals with the specific tax consequences of current distributions, including the basis of distributed property, the effects on the outside basis of the distributee partner's interest of money and property distributions, and the effects on the inside basis of the partnership's assets of in-kind distributions, as well as the effects of §751 to recharacterize non-pro rata distributions by partnerships that have §751 property and other property as taxable exchanges instead of nonrecognition distributions.
The tax consequences of liquidating distributions are discussed in Part IV, including the different rules for the basis of distributed property, and the effect on the partnership's inside basis of gain or loss recognized by the distributee partner. Liquidation of a Partnership Interest for Property E. Payments for Goodwill (1) Post January 5, 1993 Withdrawals (2) Payments For Goodwill For Which 736(b)(2) Applies 2. Further complication arises because the “tax” partnership includes not only entities organized as general partnerships or limited partnerships (“LP”) under state law, but also the newer forms of limited liability partnerships (“LLP”), initially primarily for professionals, and the increasingly popular limited liability company (“LLC”). Adjustment to Partnership's Basis in Assets Under 734(b) 1. The newer forms, particularly the LLC, have many more entity characteristics, particularly when full advantage of the freedom to contract that is part of the latest revisions of the governing statutes in most commercial states is taken into account, so that it is hard to distinguish them from corporations. Part I, Introduction, briefly discusses important general principles not directly related to distributions, but that will nevertheless frequently be referred to throughout the Portfolio, including partnership capital accounts, §704(c) and reverse §704(c) allocations. Basis of Property Received in a Current Distribution 1.