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Compensatory transfers of partnership interests raise a host of valuation issues and can trigger partnership-level gain or loss, although proposed regulations may change that in the future.
If the transaction is structured properly, the contributor's capital gains tax will be triggered when the contributor sells its partnership interests or redeems them for REIT shares or cash.
732 and allocate the tax basis of the distributed resulting partnership interest strictly in accordance with the pro rata percentage the partner is receiving (the pro rata method).
Liquidation value is the amount of cash that would have been received for the partnership interest had the partnership sold all of its assets--both tangible and intangible--for cash, immediately after the partnership interest was issued.
68 per OP Unit) as consideration for the limited partnership interests in 32 NHP partnerships in which AIMCO had acquired its general partnership interests in June 1997.
Because ownership interests in an LLP and an LLC are subject to limited liability, they are limited partnership interests.
Commissioner, [118 TC 279 (2002)], the IRS argued that a gift of a partnership interest is not really a transfer of (present) value since it is subject to restrictions on transferability and is reliant on the general partner for income distributions.
After the close of the first tax year, the partnership interests would become substantially reversed.
As a result, the gifts to be valued were fractional interests in real property rather than limited partnership interests.
They transferred certain real property and financial assets to the partnership and placed the bulk of the limited partnership interests in the children's trusts.

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