Partnership Income Taxation 6th edition by James epetti, James Repetti, William Lyons, Charlene Luke ISBN 1640207264 9781640207264

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ISBN 10: 1640207264
ISBN 13: 9781640207264
Author: James epetti, James Repetti, William Lyons, Charlene Luke

The Sixth Edition attempts the simplest possible introduction to an intricate body of law. Any “simplified” description of the rules of partnership taxation would be so misleading as to be useless. We have therefore tried to make the subject accessible not by paraphrasing the rules, but by including numerous examples that are as straightforward as possible. The text focuses on simple partnerships holding few assets and engaging in routine transactions. It places the rules in context by pointing out the purposes of the statute and regulations and presenting background information about practical matters such as how partnerships maintain capital accounts and how nonrecourse financing works. Using many examples, it then shows the operation of the rules in everyday cases encountered by practitioners. We do not offer this book as a comprehensive reference book and for that reason, we have ignored many interesting and difficult materials. Some matters, such as the application of § 736 to noncash distributions and the taxation of tiered partnerships, are not discussed at all. Most of the points that are addressed, however, are discussed at considerable length. Changes may be on the horizon; as this edition is going to press, a bill proposing a reduction to the tax rate for pass-through income is likely to be introduced in Congress and may be enacted. Numerous proposed regulations have been issued in recent years. Our goal has been to give students background material and illustrations so that they can begin to understand and work with a statute that was drafted for (and by) experienced practitioners and so that they can be prepared to make sense of any future changes. Most chapters end with a section comparing the tax treatment of partners with that of the shareholders of S corporations. Many students encountering partnership taxation for the first time have already studied subchapter S. We expect that an examination of some of the basic differences between subchapters S and K should help those students understand both subjects.

Partnership Income Taxation 6th Table of contents:

Chapter One: Choice of Entity and What Is a “Partnership” for Tax Purposes?

• A. Introduction

• B. Choice of Entity: An Overview of Taxation of Partnerships, C Corporations, and S Corporations

  • 1. Introduction

  • 2. The Flow-Through Feature of Partnerships and S Corporations vs. the Double Tax of C Corporations

    • a. Realization and Distribution of Income

    • b. Distribution of Appreciated Assets

  • 3. Allocations of Profits and Losses

  • 4. Complexity

• C. What Is a “Partnership” for Tax Purposes?

  • 1. Introduction

  • 2. Co-Ownership of Property

  • 3. Cost-Sharing and Employment Arrangements

  • 4. Partnership vs. Corporation

  • 5. Election Out of Subchapter K

  • 6. Publicly Traded Partnerships

Chapter Two: The Pass-Through Principle of Partnership Taxation

• A. Introduction

• B. Illustration

• C. The Timing of Partnership Income

• D. The Duration of a Partnership

• E. Partners as Self-Employed Taxpayers

• F. Partners and Social Security and Medicare Taxes

• G. The “Anti-Abuse” Regulations

• H. Comparison with Subchapter S

Chapter Three: An Introduction to Partnership Basis and Limits on Losses

• A. The Tax Basis of Partnership Interests and Partnership Property

• B. The Effects of Partnership Debt Transactions upon Basis

• C. Limits on the Deductibility of Partnership Losses

  • 1. Section 704(d)

  • 2. The At-Risk Rules of Section 465

  • 3. The Passive-Loss Rules of Section 469

  • 4. The “Excess Business Loss” Limitation of Section 461(l)

• D. Comparison with Subchapter S

Chapter Four: Contributions to Partnerships

• A. Contributions of Property

  • 1. The Statutory Pattern

  • 2. Holding Periods

  • 3. Contributions of Encumbered Property

  • 4. Depreciation Recapture

  • 5. Character Issues: Section 724

• B. Contributions of Services

  • 1. Receipt of an Interest in Partnership Capital

  • 2. Receipt of an Interest in Partnership Profits

  • 3. Section 1061: Short-Term Capital Gain for Partnership Interests Held in Connection with Performance of Services

• C. Contributions Distinguished from Other Transactions

  • 1. Contribution vs. Sale to Partnership

  • 2. Contribution vs. Sale or Exchange Between Partners

• D. Comparison with Subchapter S

Chapter Five: Allocations of Partnership Income, Deductions, and Credits: An Introduction

• A. An Overview of the Code and Regulations

• B. The “Substantial Economic Effect” Test

  • 1. Introduction

  • 2. Capital Accounts

  • 3. The “Simple” Capital Account Test for Substantial Economic Effect: Orrisch v. Commissioner

  • 4. The “Substantial Economic Effect” Regulations

    • a. Determining “Economic Effect” When Capital Account Deficits Need Not Be Repaid

    • b. The “Substantiality” Rules

    • c. Some Special Problems

  • 5. Sophisticated Transactions and the Substantial Economic Effect Safe Harbor

• C. Comparison with Subchapter S

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