Tax consequences of liquidating a partnership


09-May-2018 02:22

A number of problems have emerged, particularly for LLCs treated as disregarded entities, including a controversial decision by the IRS to treat the disregarded entity as the one responsible for payroll taxes for its employees, and questions about the status of recourse liabilities of a disregarded entity, particularly one that owns a partnership interest. This Portfolio analyzes not only the relevant statutory and regulatory materials, but also the large body of case law, revenue rulings, and other IRS pronouncements, including technical advice memoranda and private letter rulings, that are all part of this, unfortunately complex, body of tax law. Part I concludes with a brief discussion of the general anti-abuse regulations. Distribution to Contributing Partner - Section 737 C. Part II discusses the principles applicable to all distributions — current and liquidating — including distinguishing between them — and the general principles for nonrecognition of gain or loss on distributions of partnership property in kind, and the effect of partnership liability shifts as part of distributions.

Subsequent Sales of Distributed Property Introductory Material A. Payments in Respect of Partnership Property - Section 736(b) (1) Definition of 736(b) Payments (2) Valuation of a Partner's Interest in Partnership Property (3) Tax Consequences of 736(b) Payments (4) Section 736(b) Payments Attributable to 751 Property (5) Section 736(b) Payments - Effects on Partnership (6) Series of 736(b) Payments b. Determination of Amount Includible in Gross Estate 1.



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