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· 제목 : Partnership Taxation (Paperback, 3)
· 분류 : 외국도서 > 교육/자료 > 교육 > 교육일반
· ISBN : 9781524985806
· 쪽수 : 264쪽
· 출판일 : 2019-03-22
· 분류 : 외국도서 > 교육/자료 > 교육 > 교육일반
· ISBN : 9781524985806
· 쪽수 : 264쪽
· 출판일 : 2019-03-22
목차
- About the Author
- PART I PARTNERSHIP FORMATION
- Chapter 1 Selecting a Business Entity
- A. Sole Proprietorship
- B. General Partnership
- C. Limited Partnership
- D. Limited Liability Partnership
- E. Limited Liability Limited Partnership
- F. Limited Liability Company
- G. Corporation
- H. Tax Treatment of Business Entities under the Check-the-Box Regulations
- I. Qualified Joint Ventures between Married Persons
- J. Obtaining an Employer Identification Number (EIN)
- Chapter 2 Transfer of Property to a Partnership
- A. Nonrecognition of Gain or Loss
- B. Partner's Initial Tax Basis in Partnership Interest
- C. Partner's Holding Period in Partnership Interest
- D. Partnership's Initial Tax Basis in Partnership Assets
- E. Special Rules Relating to Character of Property Contributed
- F. Partnership's Holding Period in Partnership Assets
- G. A Partner's Capital Account
- H. Contribution of Depreciable Assets
- I. Exception to Nonrecognition: "Investment Companies"
- J. Partnership Formation Example
- Chapter 3 Transfer of Services to a Partnership
- A. Performing Services in Return for Property in General
- B. Performing Services in Return for an Interest
- in the Partnership
- 1 . Tax Treatment to the Partner
- 2 . Tax Treatment to the Partnership
- 3 . Examples
- C. Special Rule Relating to Substantially Nonvested Profits Interests Received by a Partner in Return for the Performance of Services
- Chapter 4 Other Partnership Formation Issues
- A. Taxable Year
- B. Method of Accounting
- C. Costs Related to Partnership Formation
- D. Electing Out of Subchapter K
- PART II PARTNERSHIP OPERATIONS
- Chapter 5 Ordinary Business Income and Loss, Separately Stated Items, and Adjustments to Outside Basis
- A. Pass-Through Nature of a Partnership
- B. Partnership Ordinary Business Income
- C. Separately Stated Items
- D. Nature of Partnership Reporting (IRS Form 1065)
- E. Adjustments to a Partner's Outside Basis Due to Partnership Operations (Excluding Liabilities)
- F. Example
- G. Adjustments to a Partner's Outside Basis Due to Partnership Liabilities
- H. Partnership Interest Created by Gift
- Chapter 6 Limitations on Partnership Losses Deductible by Partners
- A. Outside Basis Limitation
- B. At-Risk Loss Limitation
- C. Passive Loss Limitation
- Chapter 7 Guaranteed Payments and Other Nondistribution Transactions between Partners and the Partnership
- A. Guaranteed Payments
- B. Other Nondistribution Transactions between Partners and the Partnership
- Chapter 8 Allocations Attributable to Built-in Gain or Loss Property
- A. General Rule Relating to Allocation of Profits and Losses
- B. Regulatory Allocations Applicable to Pre-contribution Gain or Loss
- C. Example
- Chapter 9 Special Allocations, Substantial Economic Effect, and Nonrecourse Deductions
- A. General Rule Relating to Allocation of Profits and Losses
- B. Substantial Economic Effect
- C. Evolution of "Targeted" Allocations
- D. Nonrecourse Deductions
- PART III DISTRIBUTIONS FROM A PARTNERSHIP TO A PARTNER
- Chapter 10 Nonliquidating and Liquidating Distributions
- A. Nonliquidating Distributions
- B. Liquidating Distributions
- C. Death or Retirement of a Partner
- Chapter 11 Disproportionate Distributions, Disguised Sales, and Other Distribution Issues
- A. Disproportionate Distributions
- B. Disguised Sales
- C. Distributions of Contributed Property
- D. Optional Basis Adjustments to Partnership Assets (Section 754 Election)
- PART IV SALE OF A PARTNERSHIP INTEREST AND PARTNERSHIP TERMINATIONS
- Chapter 12 Sale of a Partnership Interest
- A. Gain or Loss Recognition
- B. Exception for "Hot" Assets
- C. Buyer's Initial Outside Basis
- D. Optional Basis Adjustment to Partnership Assets (Section 754 Election)
- Chapter 13 Partnership Terminations, Mergers, and Divisions
- A. Partnership Terminations in General
- B. Partnership Mergers
- C. Partnership Divisions
- PART V Miscellaneous Partnership Tax Topics
- Chapter 14 Miscellaneous Partnership Tax Topics
- A. Carried Interests
- B. Reportable Transactions and Material Advisors
- C. Anti-abuse Rules
- D. Qualified Business Income Deduction
- Index
