Tax consequences of the departure of a partner or an S corporation shareholder

Article Abstract:

The Revenue Reconciliation Act of 1993 makes an important change in liquidation payment treatment for partnership or S corporation interests by amending IRC section 736's treatment of unrealized receivables and goodwill. The previous law would have treated payments as distributive shares for which the remaining partners would receive a deduction. However, as amended, section 736 treats payments as exchanges for the partnership interest being liquidated unless capital is not a material income-producing factor and the payments are made to a general partner.

Taxation, S corporations

---

Determining a partner's share of unrealized receivables at the liquidation of the partner's interest

Article Abstract:

The author discusses the tax consequences of IRC sections 736(b) and 751(b) in regards to determining partners' shares of unrealized receivables at the time of liquidation.

Valuation

---

Corporate restructuring through partial liquidations

Article Abstract:

The author discusses the use of partial liquidations with subsidiary corporations' restructuring and pitfalls to be aware of to avoid double taxation.

Subsidiary corporations, Subsidiaries, Corporate reorganizations, Double taxation

Similar abstracts:

• Abstracts: Recovering probability distributions from option prices. A simple formula for the expected rate of return of an option over a finite holding period
• Abstracts: Report of the Committee on the financial aspects of corporate governance: the code of best practice. Paying the piper
• Abstracts: Over-reaction by security market analysts: the impact of broker status and firm size. Alternative solutions to underinvestment, under equity and credit rationing
• Abstracts: Nike & Trek announce licensing program. Fila partners with Sports Authority. Yahoo! auctions and Macy's unveil Fashion Auction
• Abstracts: The Influences of Inherent Risk and Information Acquisition on Consumer Risk Reduction Strategies. The Role of Slotting Fees and Introductory Allowances in Retail Buyers' New-Product Acceptance Decisions

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.