Prop. regs. on intangibles show caution is needed in acquiring partnership interests

Article Abstract:

Partners who plan to transfer their interests in the company should carefully study the derivation of partnership interests under all cases. In the absence of a Section 754 election, the transferee is advised to purchase an interest that was originally owned by a noncontributing partner. If the partnership holds contributed nonamortizable Section 197 intangibles and a Section 754 election is present, the transferee would usually elect to buy an interest originally owned by the contributing partner.

Tax Management, Evaluation, Tax planning

---

Accounting issues

Article Abstract:

The Proposed Regulations markedly alter the tax repercussions of the removal of a partnership under Section 708(b)(1)(B). The foremost essential effect of the alterations correlates with the way wherein the foundation of assets in a partnership is ascertained following such a dismissal of a partnership. Under the Proposed Regulations, the so-called mechanical step-up in inside basis that exists under the present regulations is eradicated.

Tax Law, Public Finance Activities, Planning, Usage, Tax administration and procedure, Tax administration

---

Accounting Issues - Life Begins at 708: Determining the Basis of Partnership Assets Following a Technical Termination

Article Abstract:

Under Section 708(b)(1)(b) of proposed regulations, a partnership terminates for tax purposes, even if it does not terminate under state law. The effects of making these tax basis determinations between partners' interests and of the partnership's assets under the Proposed Regulations, with the results under the existing regulations, are compared in this article.

United States, Cases

Similar abstracts:

• Abstracts: Accounting issues. Final regs. explain rules governing partnership contributions and distributions. Coping with the troublesome anti-abuse rules of the final mixing bowl regs
• Abstracts: Silicon Graphics rethinks entire brand. Determine what's quantifiable: association finds out if IT service marketers reach benchmarks
• Abstracts: Direct hits. Does location matter in choosing a developer? Focus your site on the customer
• Abstracts: Wrong plan investments can create unrelated business tax income. Assessment of employer FICA tax on tipped employees limited by recent cases
• Abstracts: NatWest Smaller Companies Investment Trust. HIP surgery may bring pain for investors. Exmoor's U-turn

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