Receipt of partnership interest in exchange for services: still polishing the diamond

Article Abstract:

The existing trend of recognizing an individual's management or investment expertise with a participatory joint venture interest provides a structuring challenge to the practitioner who seeks tax certainty. While the Service has offered some tips on this matter, the tax treatment of a service provider when a participatory interest is received in a partnership still needs navigating some tricky rules in search for an answer.

Tax Law, Public Finance Activities, Partnerships, Analysis, Taxation

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Selling a partnership interest after an election out of subchapter K

Article Abstract:

Sale of interest following a partnership's choice to elect out of Subchapter K regulations poses an issue of transaction definition. Since the partnership retains its status under the Internal Revenue Code's other subchapters despite election out of subchapter K rules, treatment of the sale as that of a partnership interest or as proportionate interest in each of the partnerships's assets is questioned.

Partnership distributions

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Handling the problems of forming a partnership or limited liability company

Article Abstract:

Establishing a partnership or a limited liability company is a complex process that involves a wide range tax and non-tax issues. These include the tax consequences of the classification of the business, the tax treatment of contributions and interest, and the partnership/operating agreement. These issues are explored, together with the impact of recent events of partnership/LLC formation.

Limited liability companies

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