Table of Contents 1
Cover
2
Chapter 1: Allocation of Partnership and LLC Income Under Section 704(b)
Economic effect: The general test
Deemed economic effect
Alternate test for economic effect
Substantiality
Denied allocations: Determining the partners’ or LLC members’ interests in the entity
Other issues
Allocation of deductions attributable to nonrecourse debt
Summary
Notes
3
Chapter 2: Allocations With Respect to Contributed Property: Section 704(c)(1)(A)
The traditional method
The traditional method with curative allocations
The remedial allocations method
Special rules
Summary
Notes
4
Chapter 3: Allocation of Partnership Recourse Liabilities Under Section 752
How liabilities affect partner tax consequences
Allocation of liabilities among the partners: In general
Allocation of recourse liabilities
Notes
5
Chapter 4: Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b)
Distinguishing between recourse and nonrecourse liabilities
Allocation of nonrecourse debts
Treatment of contingent liabilities
Notes
6
Chapter 5: Advanced Distribution Rules
Non-liquidating distributions generally
Distribution of multiple properties
Summary
Notes
7
Chapter 6: Adjustments to the Basis of Partnership or LLC Assets
Section 743: Adjustments following the transfer of a partnership interest
Distributions of partnership property
Allocating the adjustment amount among partnership properties
Notes
8
Chapter 7: Sale of an Interest in a Partnership or LLC
General tax consequences associated with sale
“Hot” assets and Section 751(a)
Collectibles and unrecaptured Section 1250 gain
Installment sales
Net investment income tax
Sale of an active (non-passive) interest in a partnership or LLC
Sale of a passive interest in a partnership or LLC
Purchaser of a partnership interest
Notes
10
Index
11
Solutions
Chapter 1
Chapter 2
Chapter 3
Chapter 4
Chapter 5
Chapter 6
Chapter 7
Guide 1
Cover
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