Self-employment tax, family limited partnerships and the partnership anti-abuse regulations

Article Abstract:

Use of a family limited partnership to minimize self-employment taxes may trigger application of the partnership anti-abuse regulations finalized in 1995, but planning options are available to reduce recharacterization risks. In a dual-partner family limited partnership, guaranteed payments should be made to the dual partners as compensation for services. Guaranteed payments are excluded from self-employment taxation under IRC section 1402(a)(13). If properly structured, guaranteed payments can be seen as having economic and business justifications that are not tax-motivated.

Partnerships, United States, Tax planning, Self-employed persons, Self employed persons, Partnership, Family-owned business enterprises, Family-owned businesses

---

Foreign currency transactions under the section 988 regulations

Article Abstract:

IRC section 988 regulations clarify the treatment of exchange gain or loss during a foreign currency transaction through complex, transaction-specific rules. The rules clarify the source, character, timing and computation of exchange gain or loss for such transactions as debt instrument, future and hedging. Though the rules do require transactions to be accounted for under specific rules, imposing a significant administration burden, they ease the taxpayers' burden by replacing uncertainty with specificity.

Foreign exchange, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

---

Similar abstracts:

• Abstracts: Volume, volatility, price, and profit when all traders are above average. Disclosure when the market is unsure of information endowment of managers
• Abstracts: Wrong wording kills exclusion for limited partnership interest gifts. The family limited partnership under siege
• Abstracts: Default risk in futures markets: the customer-broker relationship. Volatility in wheat spot and futures markets, 1950-1993: government farm programs, seasonality, and causality
• Abstracts: Dispute resolution: expert or arbitrator? Order, liberty and the profession. Annual conference
• Abstracts: Reluctant partners in the Westminster stand-off. Driven to work. Don't wait until our backs are against the wall

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