Section 482: its application to partnership transactions from organization to liquidation

Article Abstract:

Section 482 authorizes the allocation of income and deductions by the IRS between commonly controlled business enterprises to better determine the income of these businesses. Since the agency appears poised to intensify its examination of partnership transfer pricing issues, it is imperative for tax practitioners to deepen their understanding of the relationship between Section 482 and Subchapter K. The Section's implications for several partnership transactions are discussed.

Taxation, Transfer pricing, United States. Internal Revenue Service

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Basis of a transferred partnership interest: a will-o'-the wisp created by the new debt allocation regulations

Article Abstract:

The transfer of partnership interest is covered by final regulations of Section 752 of the Internal Revenue Code. The new Section 752 rules differ substantially from the original Section 752 and the nonpartnership Section 1001. The final rules determine the allocation of basis. Partners must consider these regulations as part of their plans to sell partnership interests.

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