Partnership Taxation
Tax Issue Spotting During the Lifecycle of a Startup
To view this presentation on tax issues relating to the formation of a startup business, click here to ...
Basic Partnership Tax II – Sales, Disguised Sales and Termination
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Sales, Disguised Sales, and Terminations
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The Basic Partnership Tax
To view this presentation on partnership taxation, click here to download a PowerPoint copy. Basic Partnership Tax - ...
Addressing Head on the Form 3115 Controversy Under the New Repair/Capitalization Regulations
In addressing the Treasury’s new repair/capitalization regulations under Code Sections 164, 168 and 263, many practitioners overlooked that ...
Tax Considerations in Choosing and Forming a Business Structure or Entity
Factors affecting the “choice of entity” can (should) include: Owner liability; Owner control and participation in management; Reporting ...
Tax Considerations in Choosing and Forming a (Business) Structure or Entity
To view this presentation on tax considerations when forming a business entity offline, click here to download a ...
Legal Alert – Critical Changes in California LLC Agreement Laws
California has dramatically changed the LLC law. Effectively, many of the "form" provisions which were customarily used in ...
Choice of Entity Outline
This article is an outline of a lecture which we recently gave at a San Francisco tax conference. ...
Partnership Tax and Disguised Sales §704(c)(1)B
There are several disguised sale rules under Subchapter K. IRC Sections 707(a)(2)(B), 704(c)(1)(B), 737 and 751(b). Needless to ...
Allocation of Debt Among Partners in Tiered Partnershipsc
This month's newsletter focuses on allocation of debt among partners in tiered partnerships. Last month we reviewed the ...
IRC 752 – Allocation of Debt Among Partners
This month's newsletter focuses on an oldie but goodie: IRC 752 — Allocation of debt among partners — ...
S Corporations
A. Basic Requirements. A corporation is eligible to elect and maintain S status only if it qualifies as ...
Tax Consequences of Liquidation of an S Corporation
The shareholder consequences of a complete liquidation of an S corporation are governed by §§ 331 and 1001. ...
IRS Posts Guidance on Changing from C Corp to S Corp
The IRS has posted on its website guidance for C corporations that wish to change to S corporation status. ...
Beyond 2036: Partnerships Post-Death
Closing the Partnership’s Books. Under IRC § 706(c)(2)(A), the taxable year of a partnership closes when a partner dies. ...
How to Avoid Indirect-Gift Treatment Under the Step Transaction Doctrine
Gross v. Commissioner (T.C. Memo. 2008-221, September 29, 2008) Ms. Gross formed a limited partnership (Dimar) in July ...
Tax Services Newsletter – Treatment of Losses from an Abandonment
This issue of the WKBK&Y newsletter addresses: Tax Treatment of Losses from an Abandonment or Worthlessness of a ...
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