Partnership Taxation 4th Edition By George Yin, Karen Burke
eBook[PDF]

Partnership Taxation 4th Edition By George Yin, Karen Burke

$30.00
✓ Secure checkout
✓ Instant digital download
✓ PDF document

Document details

Pages
269
File size
9.11 MB
Format
Digital PDF
Course
Law
Category
eBook[PDF]
About this ebook
The 4th Edition of Partnership Taxation by George K. Yin and Karen C. Burke is a comprehensive casebook focused on the intricate tax rules of Subchapter K. Structured using a conceptual "building-block" framework, it guides readers from basic formations to highly complex corporate transactions. [1, 2, 3, 4]
Core Topics & Chapters Covered
According to the textbook's curriculum and standard structure, the text primarily spans: [1, 2]
  • Choice of Entity: Analysis of how partnerships and LLCs compare to other business structures (like C corporations and S corporations).
  • Partnership Formation: Looking at tax-free contributions of property, the distinction between capital and profits interests, and avoiding disguised sales.
  • Determining Basis: Exploring "inside basis" (the partnership's basis in its assets) versus "outside basis" (a partner's basis in their partnership interest).
  • Allocation of Partnership Liabilities: How recourse and nonrecourse debt impact a partner's outside basis.
  • Calculation of Distributive Share: Substantial economic effect rules and how partnership items of income, gain, loss, deduction, and credit are shared among partners.
  • Transactions Between Partners and Partnerships: Treatment of guaranteed payments, sales, and exchanges between a partner and the entity.
  • Sales of Partnership Interests: Navigating the look-through approach, capital gains, and hot assets under Section 751.
  • Partnership Distributions: Tax consequences of current (operating) and liquidating property or cash distributions.
  • Basis Adjustments: Optional and mandatory basis adjustments resulting from transfers or distributions (Sections 754, 743(b), and 734(b)).
  • Partnership Anti-Abuse Rules: IRS policies designed to prevent the misuse of Subchapter K flexibilities. [1, 2, 3, 4, 5, 6]
New Focus Areas in the 4th Edition
This specific edition was meticulously updated to reflect crucial federal tax overhauls (up through early 2020), introducing topics such as: [1]
  • The Section 199A passthrough deduction and the 21% corporate tax rate landscape. [1]
  • Revised Treasury regulations regarding the allocation of partnership liabilities, including the elimination of bottom-dollar payment obligations. [1]
  • The Section 1061 three-year capital gain holding period mandated for service partners holding carried interests. [1]
  • The updated definition of a substantial built-in loss under Section 743(b) alongside the repeal of the technical termination rule under Section 708. [1]

File included

PDF
tmpphp8y3PCJ 9.11 MB

Topics

"outside basis" (a partner's basis in their partnership interest) Allocation of Partnership Liabilities: How recourse and nonrecourse debt impact a partner's outside basis Basis Adjustments: resulting from transfers or distributions (Sections 754 743(b) and 734(b)) Calculation of Distributive Share: how partnership items of income gain loss deduction and credit are shared among partners Choice of Entity: how partnerships and LLCs compare to other business structures (like C and S corporations) Determining Basis: Exploring "inside basis" (the partnership's basis in its assets) ISBN-13: 978-1-5438-2358-5 ISBN-13: 978-1-5438-2727-9 ISBN-13: 978-1-5438-4993-6 Partnership Anti-Abuse Rules: IRS policies designed to prevent the misuse of Subchapter K flexibilities Partnership Distributions: Tax consequences of current (operating) and liquidating property or cash distributions Partnership Formation: tax-free contributions of property Sales of Partnership Interests: Navigating the look-through approach capital gains and hot assets under Section 751 substantial built-in loss under Section 743(b) the distinction between capital and profits interests and avoiding disguised sales the elimination of bottom-dollar payment obligations the repeal of the technical termination rule under Section 708 The Section 1061 three-year capital gain holding period mandated for service partners holding carried interests Transactions Between Partners and Partnerships Treasury regulations regarding the allocation of partnership liabilities Treatment of guaranteed payments sales and exchanges between a partner and the entity
Related ebooks