Dissecting the regulations on partnership disguised sales
Article Abstract:
IRC Section 707(a)(2)(B) changes the taxable status of some contributions made by partners to partnerships. Such contributions were non-taxable prior to the enactment of Section 707, and were a favored way for partners to exchange property, pool assets and maximize profits through distributions. Section 707 was enacted after the IRS unsuccessfully tried to collect taxes on a number of such transactions that they viewed as sales. Section 707 provides for the taxation of transactions between partners that represent sales and purchase activity outside the scope of the partnership.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1993
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Indebtedness of a disregarded entity
Article Abstract:
Recourse debt and nonrecourse debt are treated differently in tax laws. However, the laws fail to clearly define what the difference is between the two types of debt. Several alterations of the tax laws should be undertaken to make this distinction more clear.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2003
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