Mastering Partnership Taxation guides students through the complex tax rules affecting partnerships and their partners. The discussion of each topic is designed to provide a basic understanding of the rules of Subchapter K of the Internal Revenue Code. It is specifically designed for students taking a class in partnership tax. Each chapter begins with a roadmap to introduce the material to be presented and ends with checkpoints that summarize the information covered. Mastering Partnership Taxation takes students through the entire life cycle of a partnership, beginning with partnership formations and ending with partnership liquidations and partnership mergers. The topics covered include: the entity v. aggregate theories of taxation; the "check the box" regulations; a comparison of partnerships to corporations and S corporations; the consequences of partner contributions to a partnership; transfers of compensatory partnership interests; an introduction to partnership accounting; an introduction to partnership debt; allocations of partnership income; partnership distributions; transactions between partnerships and their partners; and dispositions of partnership interests.

In this concise, tightly edited casebook, George K. Yin and Karen C. Burke emphasize core principles and policies to help students understand the overall structure and coherence of partnership taxation. The book’s organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses, by offering a “building-block” approach that progresses from basic to complex partnership transactions. By emphasizing the policy choices that lend structure and coherence to the law, Partnership Taxation facilitates an understanding of the overarching principles of partnership tax. Students learn the law from basic source material—the Code and regulations—as well as tightly edited cases and other guidance. Many problems, questions, and explanations supplement the presentation to guide students through the challenging material. New to the Fourth Edition: The Fourth Edition reflects developments through February 2020, including: Expanded discussion of choice-of-entity issues in light of significant changes introduced by the 2017 tax legislation, including the 21% corporate tax rate and the section 199A passthrough deduction Revised regulations concerning allocation of partnership liabilities, including disregarded bottom-dollar payment obligations The temporary expensing deduction under section 168(k), as well as new limitations on business interest deductions and excess business losses New section 1061 imposing a three-year capital gain holding period for service partners receiving partnership interests in certain investment partnerships The revised definition of a “substantial built-in loss” under section 743(b) and repeal of the technical termination rule under section 708 Professors and students will benefit from: Approach: This book emphasizes core principles and policies to help students understand the overall structure and coherence of partnership taxation. Organization: The organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses; “building-block” approach progresses from basic to complex partnership transactions. Depth: By providing in-depth coverage while avoiding unnecessary detail, the revised Fourth Edition facilitates mastery of the material and prepares students to think rigorously and creatively about the kinds of problems they will encounter as practitioners of tax and business law. Lenny faces are short character strings that describe emotions and make your text stand out.

View or download the free 2016 Online Supplement for this product. Partnership Taxation is one of several releases from the LexisNexis Graduate Tax Series. This book contains a thorough discussion of the rules of partnership taxation -- when a partnership exists, the tax treatment of contributions to a partnership, the basis of partnership assets and interests in a partnership, how income is allocated to the partners, the tax treatment of distributions, the consequences of partnership liabilities, partnership mergers, the retirement of a partner and dissolution of the partnership. There is also significant attention paid to the numerous "anti-abuse" rules that have been adopted by Congress and the IRS over the past several decades, including the disguised sale rules, the treatment of "mixing-bowl" transactions, the complex rules to prevent basis abuse, and the overriding "partnership anti-abuse regulations" adopted by the IRS. In addition, this book explores one of the fundamental questions that always arises in partnership taxation: Is a partnership to be treated as a separate taxable entity or an aggregate of its partners? The tension between entity and aggregate treatment of a partnership is one of the recurring issues in determining the tax consequences of partnership transactions. In addition to bringing the book up-to-date with the latest tax law changes and expansion of several chapters, the Third Edition contains new chapters on family partnerships, the death of a partner, and S corporations. It provides an extended discussion of allocation methods that do not have substantial economic effect, but are designed to be in accordance with the partners' interests in the partnership; series LLCs and their recently proposed regulations are also discussed in detail. The text is now suitable for both a "basic" partnership tax course (if partnership tax can ever be thought of as basic), as well as an "advanced" partnership tax course. The Teacher's Manual provides suggested syllabi for both courses.

This book provides the simplest possible introduction of partnership taxation to students and beginning practitioners trying to understand the taxation of partnerships. Partnership taxation is an intricate body of law with the result that any "simplified" description of its rules 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 over one hundred and forty examples of the rules that are as straightforward as possible. The text and examples focus on simple partnerships and limited liability companies that hold few assets and engage in routine transactions. The text 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. This is not a reference book: many interesting and difficult issues have been ignored. 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. Our goal is to give students and beginning practitioners 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 the current law and 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.

Defining partnerships and partners for tax purposes -- Formation of the partnership -- Outside basis and allocation of liabilities -- Operation of the partnership: calculation of partnership taxable income -- Operation of a partnership: allocation of partnership income and losses -- Dispositions of partnership interests -- Partnership distributions -- Transactions between partner and partnership: issuance of a partnership interest for services -- Business combinations: partnership mergers and divisions -- Partnership options -- I.R.C.: intangibles amortization -- Foreign partnerships, foreign partners and partnerships with tax-exempt entities -- Anti-abuse provisions.

This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised fifth edition reflects developments through September 2016, including proposed rules relating to compensatory profits interests and fee waivers, contributed built-in loss property, sharing of partnership liabilities and disguised sales, basis adjustments under §§ 734(b), 743(b) and 755, and § 751(b) distributions.

This comprehensive and clearly written text is designed to help students recognize and understand the basic principles and issues covered in law school courses in partnership or pass-through entity taxation at both the J.D. and LL.M. levels. It explains all the fundamental concepts and transactions affecting partnerships, limited liability companies, and S corporations and includes numerous illustrative examples, self-test questions with answers, and sample exam questions.