704(c) gain in partnership mergers

Article Abstract:

The application of Sections 704(c)(1)(A), 704(c)(1)(B) and 737 in the guidance of partnership mergers mimicking corporate 'C' reorganizations are discussed. Section 704(c)(1)(B) does not provide a partnership to partnership exception, and the regulations promulgated under Section 704(c)(1)(A) do not reach a sensible result.

Acquisitions & mergers, Partnerships, Mergers, acquisitions and divestments, Company acquisition/merger, Partnership, Corporate reorganizations

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Compliance challenges faced by pass-through entities and tax administrators: the search for uniformity continues

Article Abstract:

Pass-through entities are considered as a source of revenue for the taxing jurisdictions during periods of recession and budget crisis. Tax administrators expressed concerns about the possibility that such entities are being used for one time structure deals and one time distribution of profits.

Public Finance Activities, Tax Administration, Taxes, Corporate Tax Administration, Venture Analysis, Taxation, Corporate taxes, Tax administration and procedure, Business enterprises

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