Start-up, organizational, and syndication costs in public sales

Article Abstract:

Public sales of limited partnership interests yield particular upfront expenses that are paid out of the proceeds of the sales. Careful consideration is required for the tax treatment of three categories of the aforementioned upfront costs: startup expenses, organizational expenses and syndication expenses. For startup expenditures, the relevant provisions are contained in Sec 195, which rejects the immediate deduction of startup expenditures although Sec 195(b)(1) and 195(b)(2) contains some exemptions. As for organizational costs, Sec 197 also does not allow the immediate deduction of organizational costs, preventing one-time costs from being expenses as they are incurred. Finally, syndication fees are governed by Sec 709 as well, which means that these costs are also not deductible immediately.

Limited partnership, Limited partnerships, Going public (Securities), Initial public offerings, Cost accounting

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Tax focus on America's aging population

Article Abstract:

The aging of America has an impact on the services being offered by tax professionals. Most traditional areas of service, including estate planning, can be highlighted and updated. Meanwhile, retirement income and cash flow planning must put into consideration the longer life expectancies of the average American. Succession planning is also affected in that founders of and heirs to family businesses may have different needs, wants and desires. In light of these developments, tax practitioners should have an understanding of the tax rules regarding subject, including Social Security benefits, retirement distributions and business succession plans. This means that they should be aware of Internal Revenue Code provisions and tax planning strategies that may help retirees and other older taxpayers.

Middle aged persons, Aged, Elderly

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