Impact of Final check-the-box Regulations awaits further IRS guidance and states' input

Article Abstract:

The implementation of Section 7701 Treasury Regulations, otherwise called check-the-box Final Regulations, proved instrumental in developing tax planning opportunities of several US states. Originally adopted by the Internal Revenue Service for federal income tax purposes, the Final Regulations underscored the potential of partnership planning by establishing more flexibility and certainty of business transactions and agreements. It also facilitated interest rate transfers while preventing the occurrence of automatic dissolution through the abolition of four-factor Kintner agreements.

Tax Administration, Corporate Income Taxes, Tax planning, Business enterprises, Income tax

---

Revenue Ruling 95-41 analyzes the effect of Section 704(c) on the allocation of nonrecourse liabilities

Article Abstract:

The IRS has published Revenue Ruling 95-41 to clarify the impact of the three Section 704(c) allocation methods on the allocation of nonrecourse liabilities under Regulation Sections 1.752-3(a) through 1.752-3(a)(3). The ruling is meant to help partnerships avoid basis problems resulting from choosing a Section 704(c) allocation method.

---

Partnership liabilities: IRS interpretation helpful but further guidance needed

Article Abstract:

The Internal Revenue Service final rules of 1991 concerning the liabilities of partnerships are discussed in detail. A number of other special issues are also taken into consideration.

United States, Tax accounting, Accounting and auditing

Similar abstracts:

• Abstracts: The impact of risk regulation on price dynamics. Quantitative models for operational risk: extremes, dependence and aggregation
• Abstracts: Slicing and dicing the circulation: American Machinist matches its readers to Cincinnati Milacron's distributors
• Abstracts: London, hot spot of the world. Business locations: another record-breaking year. Business locations: on the move...but not too far
• Abstracts: Relation between the medial axis of the foot outline and 3-D foot shape. Analysis of foot shape variation based on the medial axis of foot outline
• Abstracts: Efficient consumer response meets the industrialization of agriculture. Analysis of grocery buying and selling practices among manufacturers and distributors: implications for industry structure and performance

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.