Accounting issues
Article Abstract:
Section 706(d)(2) of the Tax Equity and Fiscal Responsibility Act of 1982 wasintended to curb allocation abuses involving cash basis accounting in partnerships. This rule ensures the proportionate allocation of specific items for a partner based on their interest in the partnership. In effect, the partnership is on an accrual basis on interest, taxes, payment for services or property use and other specified items. In addition, Section 706(d)(2) also covers cash basis deductions and income items.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1992
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Coping with the troublesome anti-abuse rules of the final mixing bowl regs
Article Abstract:
The final regulations under Sections 704(c)(1)(B) and 737 contain provisions that authorize the IRS to implement certain measures to discourage abuse. These measures include imposing tax even if distributions have not been made, imposing tax on distributions made more than five years following the related contribution of appreciated property, and invalidating actual contributions. Some of the problems that can arise from these provisions are discussed.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1996
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Final regs. explain rules governing partnership contributions and distributions
Article Abstract:
The final Internal Revenue Service regulations concerning partnership contributions and distribution of appreciated property are discussed in detail. A discussion of the anti-abuse rule and other factors, such as impacts, are described.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1996
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