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The new law resolves this controversy by simply excluding corporations that hold partnership interests from the new rules.
As previously mentioned, most abandonments of partnership interests will result in the recognition of a capital loss because the reduction in liabilities allocated to the abandoning partner is treated as a cash distribution.
Thus, for example, where the partner is allocated capital gain in respect of an investment services partnership interest, the partner would be subject to ordinary income tax on a portion of that amount.
[section] 1.469-5T(e)(3)(i) provides that a partnership interest shall be treated as a limited partnership interest if it is so designated in the partnership agreement or certificate or if state law provides liability protection for the owner of the interest.
The AJCA requires mandatory basis adjustments upon the transfer of a partnership interest after October 22, 2004, by sale or exchange or upon the death of a partner, if, at the time of the transfer, the partnership's tax basis in its assets exceeds the FMV of its assets by more than $250,000 (substantial built-in loss).
If each undertaking of the partnership is a separate activity, the partnership interests should be separate as well.
83 applies to a transfer of property--including a partnership interest transfer to a service partner.
A contributor should be protected against dilution in the value of partnership interests redeemable for REIT shares by receiving distributions at the same time they are received by holders of REIT shares.
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.
A partner's holding period for a partnership interest received in exchange for a contribution of property depends on the character of the contributed property.
The existing debt holder precluded the assignment of partnership interests as collateral.
Later in 1996, the Bongard Family Limited Partnership was formed, whereby Bongard and the children's trust transferred their Class B member interest in WCB to the FLP in exchange for partnership interests. The exchange left Bongard with a 99 percent LP interest and the trust with a 1 percent GP interest.

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