Receipt of Partnership Interest in Exchange for Services: Still Polishing the Diamond

Article Abstract:

This paper discusses taxable participatory interest, i.e. when a percentage in the partnership capital and, potentially, in its profits, is given to another in exchange for his or her services. This was the subject of the Tax Court's ruling in both the cases of Diamond vs. Commissioner and Campbell vs. Commissioner under the Uniform Limited Partnership Act.

Statistical Data Included, Employee benefits

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Withdrawal Payments to Retired Law Partner Treated as Distributive Share of Partnership Income

Article Abstract:

The Internal Revenue Service ruled that payments made in complete liquidation of a partner's interest in a general partnership are deemed to be payments as a distributive share of partnership income and should be taxed as such.

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Distributive Shares and the Varying Interests Rule: Planning Ideas and Open Issues

Article Abstract:

Tax due depends on Rules determining the distributive shares in the partnership when closing the tax year is on an entity level (in respect of all the partners), or an aggregate approach (not in respect of all the partners).

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