Segregating assets within a single partnership: Delaware series partnerships and LLCs
Article Abstract:
The authors discuss Delaware's limited liability company and partnership series tax provisions.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2000
User Contributions:
Comment about this article or add new information about this topic:
When "checking the box" can lead to corporate tax savings
Article Abstract:
The authors discuss the tax law regarding "check-in-the-box" choices for corporations and when taking such elections provide corporate tax benefits.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2001
User Contributions:
Comment about this article or add new information about this topic:
Rev. Rul. 99-6 and the conversion of a partnership to a disregarded entity
Article Abstract:
The IRS's incorrect interpretation in Revenue Ruling 99-6 of its regulations under IRC section 708(b)(1) concerning termination of partnerships causes confusing and inconsistent tax treatment for buyers and sellers of all the interests in limited liability companies (LLCs). The ruling considers such transactions involving one buyer as section 708(b)(1) partnership terminations, but treats the transactions to sellers as sales of LLC interests, but to buyers as purchases of LLC assets.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1999
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Rev. proc. 2001-43 and the transfer of a nonvested partnership profits interest. Does code section 2704(b) apply in valuing a limited partnership interest
- Abstracts: Final code sec. 894 regulations: treaty benefits for hybrid entity payments. Tax Court attributes contract manufacturer's activities to principal