Review of Selected Entity Classification and Partnership Tax IssuesDistributed to some depository libraries in microfiche. |
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adjusted basis Allocating basis alternative proposal American Law Institute amount apply appreciated property business entities check-the-box regulations contributed property contributing partner corporate partner debt deduction distributed property distributee partner distribution of property distributive share eligible entity entity's fair market value Federal income tax Federal tax purposes foreign corporation foreign entity foreign tax credit gain or loss guaranteed payments indebtedness income inventory issues Kintner regulations limited liability companies limited partners limited partnership liquidating distribution marketable securities ment NESE non-depreciable capital assets ordinary income owners partner's interest partnership basis adjustments partnership capital partnership income partnership interest partnership property partnership sec partnership tax partnerships for Federal pass-through percent poration Possible Proposal pre-contribution gain present law present-law rules property distributed proposal would provide publicly traded partnership readily tradable recognized result section 754 election shareholders ship statutory subchapter supra tax rules tax treatment taxpayers tion transactions transfer Treas trust unrealized receivables