State tax withholding on nonresident partners' shares of partnership income

Article Abstract:

State taxation of nonresident partners is now commonplace in many parts of the country. Currently, California, Pennsylvania, Georgia South Carolina and seven other states are requiring partnerships in the state to withhold state income tax on the shares of partnership income or distributions of partners who do not live in the state if the income or distributions are sourced in the withholding state. The tax jurisdiction of state governments is regulated by the 14th Amendment's due process and equal protection clauses and by the US Constitution's commerce clause. These jurisdictional limits are discussed.

State taxation

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New GATT agreement may cause the recognition of gain on partnership distributions of marketable securities

Article Abstract:

US laws enacting provisions of the General Agreement on Tariffs and Trade Uruguay Round have amended IRC section 731 to limit the partnership distribution of securities without recognizing gain. Prior to the amended section 731, marketable securities distributed from partnerships were not treated like cash for purposes of gain recognition and therefore became the favored type of partnership distribution. Beginning in 1995, gain will be recognized if fair market value of the securities exceeds the recipient partner's outside basis. Marketable securities is defined very broadly.

United States, Laws, regulations and rules, Securities, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Securities taxes

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Disposition of less than an entire partnership interest: what are the tax effects?

Article Abstract:

A collection of tax ramifications should be reviewed when one partner sells a part of his interest in the partnership since the act raises countless tax issues. The identification of the proportionate interest consigned may be doubtful when the transferor holds various classes of interests or partakes in complicated profit sharing agreements. Loss limitation regulation may expose a selling partner to a tax on spurious gain.

Public Finance Activities, Corporate Tax Deductions & Exemptions, Partnerships, Corporate taxes, Loss deductions

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