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 | Tax Audit - Partnerships Edition Ebook | |
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 | |  | | E-book Category: Business, Law
E-book Title: Tax Audit - Partnerships Edition
Book Description: TABLE OF CONTENTS
Chapter 1, Initial Year Return Issues
INTRODUCTION
This chapter deals with three specific types of expenses:
Organizational Expenses
Syndication Expenses
Start Up Expenses.
Other issues covered in this chapter include the tax implications of payments made to partners:
IRC section 707(a) - Partner or Non-Partner
Receipt of a Capital or Profits Interest
Payments Capitalized, Deducted, or Distributed?
Guaranteed Payments
Chapter 2, Capital Accounts, Basis, and Liabilities
INTRODUCTION
Capital accounts
Partner's basis in his or her partnership interest
Partnership's basis in its assets
Contributions to the Partnership
Partnership liabilities
Accounting for Book/Tax differences
IRC section 754 election
Chapter 3, Contributions of Property with Built-in Gain or Loss IRC section 704(c)
INTRODUCTION
IRC section 704(c) in the context of non-depreciable property
IRC section 704(c) in the context or depreciable property IRC section 704(c) in the context of amortizable property
Impact of IRC section 704(c) on the sharing of non-recourse liabilities
The Anti-Abuse Rule
- Reverse" IRC section 704(c) which addresses re-valuations
Chapter 4, Distributions
Basics - Current and Liquidating Distributions
Disguised Sales
Distributions of Built-in Gain or Loss Property to a Noncontributing Partner
Distributions of Property to a Partner that Contributed Built-in Gain or Loss Property
Disproportionate Distributions
Chapter 5, Loss Limitations
Chapter 6, Partnership Allocations
INTRODUCTION
Factors considered in determining the partners' interests in the partnership
Economic effect
Substantiality
Allocation of items attributable to non-recourse debt
Allocation of tax credits
Chapter 7 Dispositions of Partnership Interest
INTRODUCTION
A partner can dispose of a partnership interest in the following ways:
By sale to one or more of the other partners.
By sale to a third party.
By exchange of the partnership interest for other property.
By transfer back to the partnership in return for at least one liquidating distribution leading to a complete liquidation of the partnership interest.
By retirement.
By gift or contribution.
By death.
By surrendering the partnership interest through abandonment, forfeiture, or worthlessness of the partnership interest. Each of the above methods for disposing of a partnership interest is covered in this chapter.
This chapter also addresses:
The character of the gain or loss on the disposition of a partnership interest.
The effect of related debt disposition.
The recognition of accumulated suspended passive losses associated with a partnership interest.
Chapter 8 Real Estate Issues in Partnerships
INTRODUCTION
Approximately 50 percent of all partnerships are involved in the real estate business. A partnership may be involved in real estate development, construction, or leasing. Even though a partnership may not be involved in a real estate business it may own or lease real estate. This chapter covers various tax issues related to real estate such as:
Cancellation of Indebtedness
Tufts/ Non-recourse Debt and Unpaid Interest
Accrued Contingent Interest
Bankruptcy
Low Income Housing Tax Credit
Zombie Partnerships
Uniform Capitalization - IRC section 263A
Chapter 9, Tax Shelters
INTRODUCTION -- This chapter covers:
Corporate Tax Shelter Characteristics
Office of Tax Shelter Analysis
Tax Shelter Disclosure
Partnership Anti-Abuse Regulations
Sham Partnership/Sham Partners
Judicial Doctrines
Chapter 10 International (Reserved)
Chapter 11, Family Partnerships
Chapter 12, Syndicated Investment Partnerships
Chapter 13 TEFRA GLOSSARY
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