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[DOC File]Chapter 3 – Receipt of a Partnership Interest for Services
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On that date, O sells his interest in the partnership to unrelated buyer G for $62,000. How much gain or loss will O recognize in connection with the sale to G? The tax basis of O’s partnership interest is $59,000. Thus, a sale of this interest for $62,000 will trigger a taxable gain of $3,000. What will be the character of O’s gain or loss?
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[DOC File]AICPA Comments on Proposed Regulations Relating to the ...
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Reconciling Section 721 Treatment to the Creditor with Section 108(e)(8) Treatment to the Partnership. Section 721(a) provides that no gain or loss shall be recognized to a partnership or any of its partners in the case of a contribution of property to the partnership in exchange for an interest in the partnership.
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[DOC File]The Troubled Partnership - Workouts and Debt Restructurings
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Partnership liabilities also can be reduced by a sale or distribution of encumbered partnership property. ... For these purposes FMV of a partnership interest is the liquidation value of the partnership interest if certain requirements are met. ... What are the tax consequences of the treatment of the deemed extinguishment of debt between a ...
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[DOC File]Chapter 10
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The distinction between the two types of nonliquidating distributions is largely semantic, since the basic tax treatment typically does not differ. Example: Kay joins the calendar year KLM Partnership on January 1 by contributing $40,000 cash to the partnership in exchange for a one-third interest in partnership capital, profits, and losses.
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[DOC File]Chapter 10
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When capital is a material income-producing factor and a partnership interest is transferred by gift or sale to a child who is under age 19 (or 24), the kiddie tax may apply. Under the kiddie tax, some of the dependent child’s distributive share of partnership income may be taxed at the parent’s tax rate, unless the income share constitutes ...
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[DOC File]L n
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There are three options to raise additional money: (1) capital contributions from investors, (2) a loan to the partnership, or (3) the sale of the limited partner’s interest in the partnership. Capital Contribution from new Investors. Capital contributions from new investors would raise money for the partnership in a tax free manner.
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[DOC File]Mandatory Section 734(b) and Section 743(b) Adjustments to ...
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Section 751(a) generally treats gain or loss on the sale of a partnership interest as ordinary to the extent it is attributable to ordinary income property held by the partnership. Until 1997, section 751(a), like current section 751(b), applied only to a partnership’s inventory items were substantially appreciated.
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[DOC File]TAX STRATEGIES FOR CORPORATE ACQUISITIONS,
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A transferee’s interest as a partner in the partnership’s previously taxed capital is equal to (i) the amount of cash that the transferee would receive on liquidation of the partnership following a hypothetical sale (immediately after the transfer of the partnership interest to the transferee) of the partnership’s assets in a fully ...
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[DOC File]Income taxation of sovereign wealth funds
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The exemption applies to interest, dividends and capital gains from dealings in stocks, bonds and other securities. The exemption also applies to capital gains received on the sale of stock in a US real property holding company. On the other hand, gains from the sale of a directly owned US real property interest would be subject to tax.
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[DOC File]AICPA Comments on Proposed Regulations Addressing ...
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Clarify the Tax Treatment of Issuing Noncompensatory Partnership Options. ... a partner generally recognizes ordinary income or loss on the sale of its partnership interest to the extent such partner would have been allocated ordinary income or loss if the partnership sold its section 751 assets in a fully taxable transaction. The option holder ...
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Sale of partnership interest tax treatment