'Hypothetical sale' approach makes real change in partnership regs

Article Abstract:

The author details IRS regulations which change the tax treatment of transfers of partnership interests. Gain and loss recognition provisions differ from prior law. Several examples which focus upon bases calculations are included.

Tax Law, Public Finance Activities, Partnerships

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New regs. offer guidance on partnership adjustment allocations

Article Abstract:

The author discusses regulations under IRC section 743(b) regarding the taxation of partnership adjustment allocations.

Basis (Taxation), Allocation (Taxation), Tax allocation

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Single sale generates multiple types of capital gains

Article Abstract:

The author examines IRS final regulations for IRC section 1(h)(11) regarding capital gains recognition on the sale or exchange of partnership, S corporation, or trust interests.

S corporations, Trusts and trustees, Trustees, Trusts (Law), Capital gains tax, Business sale

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