Accounting transaction for liquidating partnership
The discussion in this Portfolio involves not only analyzing the relevant statutory and regulatory materials, but also the large body of case law, revenue rulings, and other IRS pronouncements, including technical advice memoranda and private letter rulings, that are all part of this, unfortunately complex, body of tax law.
Further complication arises because the “tax” partnership includes not only entities organized as general or limited partnerships under state law, but also the newer forms of limited liability partnerships, primarily for professionals, and the, increasingly popular, limited liability company. Basis Consequences (1) Effect on Inside Basis (2) Adjusting Purchaser's Share of Inside Basis - § 754 and Substantial Built-In Loss (a) Computing the Inside Basis Adjustment (b) Effect of the Residual Method (i) Application of the Residual Method (ii) Shares of Partnership Assets (c) Tiered Partnerships e. 18 upon a Loss of Significant Influence (Issue Date October 6, 2005) [Full Text] [Status] FSP FAS 13-2—Accounting for a Change or Projected Change in the Timing of Cash Flows Relating to Income Taxes Generated by a Leveraged Lease Transaction (Issue Date April 9, 2009) [Full Text][Status] FSP FAS 117-1—Endowments of Not-for-Profit Organizations: Net Asset Classification of Funds Subject to an Enacted Version of the Uniform Prudent Management of Institutional Funds Act, and Enhanced Disclosures for All Endowment Funds (Issue Date August 06, 2008) [Full Text] [Status] FSP FAS 123(R)-1—Classification and Measurement of Freestanding Financial Instruments Originally Issued in Exchange for Employee Services under FASB Statement No.123(R) (Issue Date November 10, 2005) [Full Text] [Status] FSP FAS 123(R)-4—Classification of Options and Similar Instruments Issued as Employee Compensation That Allow for Cash Settlement upon the Occurrence of a Contingent Event (Issue Date December 30, 2008) [Full Text] [Status] FSP FAS 133-1 and FIN 45-4—Disclosures about Credit Derivatives and Certain Guarantees: An Amendment of FASB Statement No. 45; and Clarification of the Effective Date of FASB Statement No. 9059, Regulations on Coordination of Sections 7; Allocation of Basis Adjustments Among Partnership Assets and Application of the Residual Method to Certain Partnership Transactions, 68 Fed. 4293 (6/9/03) Worksheet 6 Preamble to REG-107872-99, Proposed Regulations on Coordination of Sections 7 Relating to Allocation of Basis Adjustments Among Partnership Assets, 65 Fed. 8847, Adjustments Following Sales of Partnership Interests, 64 Fed. 69903 (12/15/99) Worksheet 8 Preamble to REG-209682-94, Proposed Regulations on Adjustments Following Sales of Partnership Interests 63 Fed. As with all other aspects of partnership taxation, the dual nature of a partnership for tax purposes — as at times an aggregation of its partners, and at times an entity — complicates the discussion, particularly, because no one, including the author, has been able to articulate a comprehensive statement of when the aggregate, and when the entity, aspect should predominate. Transfer to Controlled Corporation, or in Reorganization e. Section 754 Election (1) Successor's Basis Adjustment under § 754 (2) Basis Adjustment Without § 754 Election - § 732(d) b.
Further complication arises because the “tax” partnership includes not only entities organized as general or limited partnerships under state law, but also the newer forms of limited liability partnerships, primarily for professionals, and the, increasingly popular, limited liability company. Tiered Partnerships (1) Transfer to Upper-Tier Partnership (2) Distribution by Upper-Tier Partnership (3) Mixing Bowl Transactions (a) Contributed Property Distributed to Another Partner (b) Other Property Distributed to Contributing Partner f. Valuing Deceased Partner's Interest (1) Buy-Sell Agreements (2) Valuation Discounts and Premiums c.
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Accounting and Reporting by Mutual Life Insurance Enterprises and by Insurance Enterprises for Certain Long-Duration Participating Contracts—an amendment of FASB Statements 60, 97, and 113 and Interpretation No.
Allocating Price - § 1060 (1) Amount Allocated (2) Residual Method (3) Amortization of Intangibles by Purchaser - § 197 b.
Distribution and Contribution of Partnership Assets (Assets-Up) c.
25498 (5/9/97) Partnership Termination Worksheet 10 Preamble to T. 8925, Regulations on Partnership Mergers and Divisions, 66 Fed. 715 (1/4/01) Worksheet 11 Preamble to REG-111119-99, Proposed Regulations on Partnership Mergers and Divisions, 65 Fed. 1572 (1/11/00) Worksheet 12 Preamble to REG-106736-00, Proposed Regulations on Assumption of Partner Liabilities, 68 Fed.