TreatiseTreatise

The Partnership Tax Practice Series

 by Louis S Freeman, Clifford M Warren
 
 Copyright: 2010-2017
 Last Updated: August 2017

 Product Details >> 

Product Details

  • ISBN Number: 9781402414268
  • Page Count: 20374
  • Number of Volumes: 16
  •  

The Partnership Tax Practice Series includes more than 425 articles written by over 290 prominent partnership tax practitioners and delivers a sound analysis of cutting-edge transactional tax-related issues and innovative solutions for highly effective tax planning results. Laying a foundation with guidance on drafting and negotiating partnership and LLC agreements, The Partnership Tax Practice Series then examines more complex issues, including the tax treatment of private equity and hedge funds, debt workouts, and the latest guidance involving disguised sales  To provide a historical framework for today’s partnership tax practice, the series includes retrospectives on significant developments in partnership and real estate taxation, interesting partnership transactions of the past decade, and analysis of major decisions, including Hubert, Canal Corporation, G-I Holdings and Castle Harbour.

Major topics include:

  • Basic calculation
  • Allocation of partnership liabilities
  • Partnership exit strategies
  • Partnership mergers and divisions, including the anti-mixing bowl rules
  • Tiered partnerships
  • Taxation and use of real estate investment trusts (REITs)
  • Dealing with LLC partnership equity compensation
  • Partnerships in the public space
  • COD income deferral guidance
  • Tax shelters, the partnership anti-abuse rules, the economic substance doctrine and tax penalties
  • International partnership and joint venture issues
  Table of Contents
Chapter 1: The Partnership Union: Opportunities for Joint Ventures and Divestitures
Chapter 2: Partnership Joint Ventures of Operating Business
Chapter 3: Final Section 197 Regulations: Application to Partnership Transactions
Chapter 4: Section 197 and Partnership Transactions
Chapter 5: Enough Anti-Churning: It’s Time to Make Butter
Chapter 11A: Partnership and LLC Agreements—Learning to Read and Write Again
Chapter 12: Significant Developments in Partnership Taxation 2003-2004
Chapter 13: Significant Developments in Partnership Taxation 2004-2005
Chapter 14: Significant Developments in Partnership Taxation 2006-2007
Chapter 15: Significant Developments in Partnership Taxation 2007-2008
Chapter 16: Significant Developments in Partnership Taxation 2008-2009
Chapter 16B: Developments in Partnership and Real Estate Taxation in 2010
Chapter 16C: Developments in Partnership and Real Estate Taxation in 2011
Chapter 16D: Developments in Partnership and Real Estate Taxation in 2012
Chapter 16E: Developments in Partnership and Real Estate Taxation in 2013
Chapter 16F: Developments in Partnership and Real Estate Taxation in 2014
Chapter 16G: Recent Developments in Partnership and Real Estate Taxation
Chapter 17: Getting Down to Business: Partnerships and Miscellaneous Itemized Deductions
Chapter 17A: Planning for Real Estate Professionals and Investors Under the Net Investment Income Tax and the Self-Employment Tax
Chapter 17B: Impact of the 3.8 Percent Net Investment Tax on Alternatives
Chapter 17C: Proposed Net Investment Tax Regs’ Impact on Alternatives
Chapter 17D: Final Net Investment Tax Regs’ Impact on Alternatives
Chapter 17E: Partners and the 3.8% Taxes: FICA, SECA, NIIT, or Nothing?
Chapter 18: Selected Partnership Case Studies
Chapter 24B: Interesting Partnership Transactions of 2011 (PowerPoint slides)
Chapter 24C: Interesting Partnership Transactions of 2012 (PowerPoint slides)
Chapter 24D: Interesting Partnership Transactions of 2013 (PowerPoint slides)
Chapter 25: Opening Pandora’s Box: Who Is (or Should Be) a Partner?
Chapter 27: When Is a Partner Not a Partner?
Chapter 28: The Uncertain Certainty of Being a Partner: Classification as a Partner for Tax Purposes
Chapter 30: A Catalogue of Legal Authority Addressing the Federal Definition of Tax Partnership
Chapter 31: Rev. Proc. 2001-43, Section 83(B), and Unvested Profits Interests—The Final Facet of Diamond?
Chapter 32: Compensating the Service Partner with Partnership Equity: Code §83 and Other Issues
Chapter 34: A Layman’s Guide to LLC Incentive Compensation
Chapter 35: Proposed Regulations on Partnership Interests Issued for Services: Practical Problems and Opportunities
Chapter 36: Prop. Regs. on Partnership Equity for Services: The Collision of Section 83 and Subchapter K
Chapter 37: Proposed Partnership Equity Compensation Regulations: “Little or No Chance” of Satisfying Everyone
Chapter 38: Proposed Regulations on Partnership Equity for Services: Illustrative Examples
Chapter 39: First IRS Ruling on Unvested Partnership Profits Interests: No Income Recognized but Questions Remain
Chapter 41: Employment and Self-Employment Taxes for Partners
Chapter 42: The Application of SECA and NIIT to Investors and Managers of Asset Management Funds
Chapter 42A: Delimiting Limited Partners: Self-Employment Tax of Limited Partners
Chapter 42B: The New Deal: Hedge Fund Management Fees Are Subject to Social Security Taxes
Chapter 43: Selected Tax Issues in Equity-Based Compensation for Partnerships and LLCs
Chapter 45: IRS Hearing on Proposed Regulations “Disguised Payments for Services” [REG-115452-14]
Chapter 46: Taxation of Carried Interests
Chapter 46A: Practical Considerations for Issuing Profits Interests
Chapter 46B: Crescent Holdings: The Once and Future Partner That Was Not
Chapter 48: Taxing Partnership Profits Interests as Compensation Income
Chapter 49: Taxation of Service-Connected Property Transfers Under Code Section 83
Chapter 49A: Should My CEO Be My Partner? A Practical Approach to Dealing with LLC and Partnership Equity Compensation
Chapter 50A: New York State Bar Association Tax Section Report on the Proposed Regulations on Disguised Payments for Services
Chapter 51: Tax Planning for Partnership Options and Compensatory Equity Interests
Chapter 52A: Equity and Equity-Related Compensation: A Jaunt Through Sections 83, 409A, 457A and Proposed Section 710
Chapter 53: Section 83(b), Section 409A, Section 457A, and Subchapter K
Chapter 54: Employee Benefits Considerations in Joint Ventures
Chapter 55: U.S. Partnership Retirement Plan Considerations
Chapter 56: Noncompensatory Partnerships Options: The Final Regulations
Chapter 56A: Options and Convertible Interests for LLCs Taxed as Partnerships
Chapter 56B: Final and Proposed Regulations Regarding Partnership Noncompensatory Options
Chapter 57: Noncompensatory Partnership Options
Chapter 58: Basis Calculations for ‘Real’ Partners
Chapter 59: Partnership Interest Basis Issues
Chapter 60: Planning Partnership Admissions and Book-ups
Chapter 60A: Partnership Book-ups
Chapter 63: A Framework for Evaluating Anticipatory Allocations
Chapter 65: Guarantees, DROs, and CCOs: Getting Partnership Liability Allocations Right
Chapter 65A: A ‘Guaranteed’ Debacle: Proposed Partnership Liability Regulations
Chapter 66: The Liability-Offset Theory of Peracchi
Chapter 67A: New York State Bar Association Tax Section Report on the Treatment of Exculpatory Liabilities for Purposes of Section 704 and Section 752
Chapter 67B: The Target Method for Partnership Special Allocations and Why It Should Be Safe-Harbored
Chapter 67C: IRS Blunders in Treatment of NRCOs in CCA 201606027
Chapter 69: Simple Distributions from Leveraged Partnerships
Chapter 69A: The Math Behind Financial Concepts in Real Estate Partnership Distribution Waterfalls
Chapter 70: The Impact of Disregarded Entities on Partnership Liability Allocations: Proposed Regulations Under I.R.C. Section 752
Chapter 71: New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 71A: The IRS Did What to the Partnership Debt Allocation and Disguised Sale Rules?!?
Chapter 71B: Proposed Regulations Address Debt Allocations for Partners and Related Parties
Chapter 72: Proposed Regulations on Debt Allocations: Controversial, and Deservingly So
Chapter 73: New Partnership Liability Regulations Target Abuse but Sweep More Broadly
Chapter 73A: Put a “Bottom” Deficit Restoration Obligation in Your Partnership Liability Allocation Tool Box
Chapter 74: Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
Chapter 75: Planning for Partnership Liability Allocations Including the New Proposed Regulations
Chapter 76: "Bad Boy" Nonrecourse Carve-Outs in Real Estate Loan Cause It to Be Recourse—or Do They?
Chapter 77: Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 77A: Capital Account-Based Liquidations: Gone with the Wind or Here to Stay?
Chapter 79: Drafting Partnership Agreements for Substantial Economic Effect (PowerPoint slides)
Chapter 80: Annotated Tax Provisions for Limited Liability Companies
Chapter 81: Hedge Fund Stuffing Allocations: A Path Through the Maze
Chapter 81A: The Problem with Stuffing Allocations
Chapter 83: Ruminations on Substantiality Under the Section 704(b) Regulations
Chapter 84: Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down
Chapter 85: A Partner’s Interest in the Partnership for Purposes of Section 704(b)
  • • : Appendix A: Capital Accounts, Who Needs Them?85-73
Chapter 87: FAQ-Filled Guidance on Computing a Partner’s Interest in Profits, Losses, and Capital—Part 1
Chapter 88: FAQ-Filled Guidance on Computing a Partner’s Interest in Profits, Losses, and Capital—Part 2
Chapter 88A: LLC Capital Shifts: Avoiding Problems When Applying Corporate Principles
Chapter 89: In Search of Partners’ Interests in the Partnership: The Alternative to Substantial Economic Effect
Chapter 94: The Impact of a Capital Account Deficit Restoration Obligation on a Partner’s At-Risk Amount and Share of Liabilities: Hubert Enterprises, Inc. v. Commissioner
Chapter 95: Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case
Chapter 96: Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 97: Passive Losses, LLCs and LLPs—Courts Reject IRS’ Attempt to Limit Losses
Chapter 99: A Primer on Allocations with Respect to Contributed and Revalued Property Section 704(c)
Chapter 100: American Bar Association Section of Taxation Comments on Proposed Regulations on Certain Partnership Provisions of the American Jobs Creation Act of 2004
Chapter 101: Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 102: Planning Opportunities Remain Under the Final Partnership Allocation Rules for Contributed Property
Chapter 103: Section 704(c) and the Regulations Thereunder
Chapter 104: The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 105: Making Section 704(c) Sing for You
Chapter 106A: The Proposed Regulations Under Sections 704(c)(1)(C), 734, 743, 755
Chapter 106B: Contribution of a Built-In Loss to a Partnership
Chapter 107: Disharmony in the Search for Purity in Section 734(b) Common Basis Methodology: Interfaces with Section 704(c) Built-In Gain Shares and Outside Basis (PowerPoint slides)
Chapter 108: New York State Bar Association Tax Section Report on the Proposed Regulations on Partnership Built-in Losses
Chapter 109: Notice 2009-70: A Focus on Complex Section 704(c) Netting Versus Layering Issues
Chapter 110: Revaluations Revisited: Partnership Allocations and the Demise of the Ceiling Rule
Chapter 110A: New York State Bar Association Tax Section Report No. 1361 on Proposed and Temporary Regulations Under Sections 707 and 752
Chapter 111: Partnership Disguised Sale Rules
Chapter 111A: Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 113: Gateway Hotel Partners: Decision Illustrates the Disguised Sale Quandary
Chapter 115: An Analysis of the Rules Governing Disguised Sales to Partnerships: Section 707(a)(2)(B)
Chapter 116: New Proposed Regulations on Disguised Sales of Partnership Interests
Chapter 117: Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 117A: Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
Chapter 117B: Tax Court Goes Overboard in Canal
Chapter 117C: The Tax Court Drains Canal Corporation
Chapter 117D: Implications of Canal Corporation for Structuring Partnership Transactions
Chapter 117E: Send Not to Know for Whom the Bell Tolls
Chapter 117F: SWF Real Estate: Tax Credits and Disguised Sales—Reasons for Concern
Chapter 119: Final Regulations Under Sections 704(c)(1)(B), 737 and 731(c)
Chapter 121: Partnership Mixing-Bowl Issues (PowerPoint slides)
Chapter 122: Creative Partnership Exit Strategies
Chapter 123: Partnership Exit Strategies and the Failure of the Substantiality Test
Chapter 124: Deceptive Simplicity: Continuing and Current Issues with Guaranteed Payments
Chapter 126: Selling Your Partnership Business?—You Have Two Choices with Different Tax Consequences
Chapter 127: The Tax Consequences of Partnership Break-Ups: A Primer on Partnership Sales and Liquidations
Chapter 128: New Taxpayer Favorable PLRs Allow Gain on Sale of Partnership Assets to Be Offset by Disallowed Loss on Earlier Sale of Partnership Interest
Chapter 129: Redeeming a Partner with the Partnership’s Note
Chapter 129A: The Tax Treatment of Earnouts in Business Acquisitions
Chapter 129B: Assumed Liability Deductions
Chapter 129C: Code Section 736: A Retiring Partner Case Study Involving Flexible Payments
Chapter 130: Paying for Assumption
Chapter 131: Partnership Distributions of Marketable Securities
Chapter 132: Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner
Chapter 133: A Comprehensive Guide to Partnership Terminations, Including the New Proposed Regulations
Chapter 135: Planning for Partnership Distributions with Respect to Redemptions, Withdrawals, Retirements, Dismissals, Expulsions, Terminations, Liquidations, and Deaths of Partners
Chapter 136: Order in the Court: Why Ordering Matters in Partnership Transactions
Chapter 138: The Treatment of Liabilities in Rev. Rul. 99-5 and Rev. Rul. 99-6 Situations
Chapter 138B: Overshooting the Mark? Section 751, Sale of Goodwill, and the Assignment of Income Doctrine
Chapter 139: Operational Issues of Section 751(b)—Current and Future (PowerPoint slides)
Chapter 140: New York State Bar Association Tax Section Proposed Regulations Under Section 751(B)
Chapter 141: American Bar Association Section of Taxation Comments on Section 751(b) Proposed Regulations
Chapter 143: Applying Sections 704(c) and 737 in Partnership Mergers and Divisions
Chapter 144: Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 145: Partnership Mergers and Divisions: A User’s Guide
Chapter 146: Partnership Mergers and Divisions
Chapter 147: Creative Transactional Planning Using the Partnership Merger and Division Regulations
Chapter 148: Partnership Mergers: The Saga Continues
Chapter 149: Transactional Planning Under the Partnership Merger & Division Regulations
Chapter 150: Mergers and Divisions of Partnerships
Chapter 151: Mergers & Acquisitions Involving Partnerships
Chapter 152: Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service Be So Wrong?
Chapter 153: Mapping the Labyrinth: Partnership Mergers and Divisions
Chapter 154: Recapitalization of Partnerships: General Issues Under Subchapter K
Chapter 155: M&A Transactions Involving Partnerships and LLCs, Including Conversions, Mergers and Divisions
Chapter 159: JOBS Act Tightens Partnership Tax Rules
Chapter 162: A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 163A: Tiers of Partnerships and Corporations: Does the Chain’s Length Change the DNA?
Chapter 163B: The 80-Percent Dividends-Received Deduction Under Section 243: Does a Partnership Mess It All Up?
Chapter 164: The "Check-the-Box" Regulations: Elective Entity Classification Under Section 7701
Chapter 165: Tax Planning for Single Member Entities: Check-the-Box, Qualified REIT Subsidiaries and S-Corp Subsidiaries
Chapter 166: Entity Identity: The Taxation of Quasi-Separate Enterprises
Chapter 167: Tax Classification of Segregated Portfolio Companies
Chapter 169A: First Steps—Proposed Regulations on Series LLCs Provide Clarity
Chapter 169B: Series LLC—Is It Finally Usable?
Chapter 171: Use of Limited Liability Companies in Corporate Transactions
Chapter 172: Disregarded Entities: Issues and Opportunities
Chapter 172A: Now You See It, Now You Don’t: The Comings and Goings of Disregarded Entities
Chapter 173: Due Regard for Disregarded Entities
  • • : Supplement to Due Regard for Disregarded Entities (February 1, 2017)173-29
Chapter 174: Through the Looking Glass: Seeing Corporate Problems as Partnership Opportunities
Chapter 175: How and When to Apply Step Transaction Doctrine in Corporate and Partnership Restructuring Transactions
Chapter 176: New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 176A: The Umbrellas of Subchapter K
Chapter 176B: The Up-C Revolution
Chapter 177: The Corporation as Partner Tax Reasons and Tax Effects
Chapter 178: Opportunities and Pitfalls for the Property Owner in Transactions with a REIT
Chapter 179: Taxation of Real Estate Investment Trusts and Shareholders
Chapter 179A: Federal Income Tax Aspects of REITs
Chapter 181: The Private REIT: Selected Tax Issues
Chapter 181A: Back to the Future: UPREIT Deals Are Back Opportunities and Pitfalls in Structuring UPREIT Transactions
Chapter 183: The S Corporation Rules and the Use of S Corporations as Acquisition Vehicles
  • • : Appendix183-233
Chapter 186: The "State of the Art" in Like-Kind Exchanges, 2009
Chapter 187: Tax Court Again Rejects Purchase from a Related Person of 1031 Replacement Property
Chapter 187A: IRS Provides Limited Relief for Section 1031 Exchanges That Fail Due to Default by a QI
Chapter 188: The ‘State of the Art’ in Like-Kind Exchanges—2015
Chapter 188A: Eighth Circuit Sheds Light on Like-Kind Exchanges
Chapter 189: Aligning the Stars—Estate Planning for Entrepreneurs in Interesting Times
Chapter 191: Hedge Fund Tax Considerations
Chapter 192A: Federal Income Tax Treatment of Hedge Funds, Their Investors, and Their Managers
Chapter 193: U.S. Taxation of Private Equity and Hedge Funds
Chapter 194: Exploring the Reasons Behind the Bias of Private Equity and Venture Capital Firms Investing in Corporations Rather Than Limited Liability Companies—A Time to Reconsider
Chapter 197: Taxation of United States Tax-Exempt Entities' Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization
Chapter 198: UBIT Issues in Investment Partnerships: What Tax-Exempt Organizations (and Their Taxable Partners) Should Know
Chapter 199: Joint Ventures with Tax-Exempt Entities and Taxable Operations (Including REITs)
Chapter 199A: A Guide to Election Year Activities of Section 501(c)(3) Organizations
Chapter 200: Help with Fractions: A Fractions Rule Primer
Chapter 202: Possible Approaches for Avoiding UBTI on Real Estate Investments
Chapter 203: Certain U.S. Tax Considerations for Organizing U.S. Hedge Funds
Chapter 204: Cross-Border Tax Problems of Investment Funds
Chapter 205: U.S. Taxation of Tax-Exempt and Foreign Investors in U.S. Private Investment Funds
Chapter 206: Partnerships as an Alternative to Secured Loans
Chapter 207: Debt vs. Equity in the Partnership Context
Chapter 208: Partner or Lender? Debt/Equity Issues Arise in Second Circuit’s Reversal of Castle Harbour
Chapter 209: Economic, Tax, and Drafting Considerations for Preferred Partnership Interests
Chapter 209A: New York State Bar Association Tax Section Report on Guaranteed Payments and Preferred Returns
Chapter 210: Revival of the Choice of Entity Analysis: Use of Limited Liability Companies for Start-Up Businesses and the “Up-C” Structure
Chapter 210C: Should There Be One Set of Passthrough Rules for All Non-Publicly Traded Businesses? (Option 2 of the Ways and Means Committee draft to reform the taxation of small businesses and passthrough entities)
Chapter 211: Organizing the Corporate Venture
Chapter 214: Noted Trends in the State Taxation of Pass-Through Entities
  • : Preamble: State Tax Treatment of LLCs and LLPs214-9
  • : Chart 1: State Tax Treatment of Limited Liability Companies and Limited Liability Partnerships214-11
  • : Chart 2: Tax Treatment of LLCs/LLPs/LPs (“LLEs”) by States Imposing Net Worth- Or Debt-Based Corporate Franchise Taxes214-31
Chapter 215: A Primer on Income Tax Compliance for Multistate Pass-Through Entities and Their Owners
Chapter 216: Select Transactional Issues in State Partnership Taxation
Chapter 217: Limited Liability Company Conversions—Navigating the State Tax Implications
Chapter 218: Publicly Traded Partnerships
Chapter 218A: Partnerships in the Public Space
Chapter 219: Section 7704 and Publicly (or Non Publicly) Traded Partnerships
Chapter 224: United States Federal Taxation of Derivatives: One Way or Many?
Chapter 225: Debt Workouts: The Partnership and the Partners
Chapter 225A: New COD Income Deferral Guidance Allows Flexibility for Partnership
Chapter 225B: Taxation Meets Bizarro World: Passthroughs and Debt Workouts
Chapter 226: Partnership COD Income and Other Debt Issues
Chapter 226A: Recourse or Nonrecourse: Liability Treatment for COD, Other Purposes
Chapter 226B: Is It Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas Out of Great Plains Gasification
Chapter 226C: The Mysterious Case of Disappearing Debt in Partnership Transactions
Chapter 226D: Planning for Section 108 Relief
Chapter 226F: IRS Helps Insolvent Partners in Revenue Ruling 2012-14
Chapter 228: Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss
Chapter 229: Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 230: Worthless Partnership Interests
Chapter 232: Partner Guarantees in Debt Workouts
Chapter 234: Debt Workout Issues for REITs Are Complicated, Whether They Are Debtors or Creditors
Chapter 235: Partnership Bankruptcy Tax Issues
Chapter 238: A Short History of Tax Shelters
Chapter 240: Joint Committee on Taxation: Report of Investigation of Enron Corporation and Related Entities Regarding Federal Tax and Compensation Issues, and Policy Recommendations (Excerpts Relating to Partnership Tax Issues)
Chapter 241: Broad Scope of Section 470 Catches Many Non-Abusive Transactions
Chapter 242: Here Comes the Kitchen Sink: IRS Throws “Everything But” at Two Partnership Tax Deferral Structures
Chapter 243: Son of BOSS Transactions: Taxpayers Win the First Round in Klamath
Chapter 244: What Will Be the Impact of the Government’s Victory in Coltec?
Chapter 245: What Will Be the Long-Term Impact of the Sixth Circuit’s Divided Decision in Dow Chemical?
Chapter 246: Will Black & Decker Turn Out to Be a Pyrrhic Victory for the IRS?
Chapter 247: The STARS Continue to Revolve—The First Appellate Decision
Chapter 248: Klamath Dispatches Another Tax Shelter, but Without Penalties
Chapter 249: LILO Transaction Upset by District Court on Motion for Summary Judgment in BB&T
Chapter 250: ‘Son of BOSS’ Update: Summary Judgment on the Tax Liability in Cemco but No Fraud in Sala
Chapter 251: Chemtech—The Fifth Circuit Reins in but Upholds the District Court
Chapter 253: Taxable Sale or Nontaxable Reorganization? Tax Court Draws a Distinction in Tribune Company
Chapter 254: Court of Federal Claims Rejects Taxpayer’s Claims of a Business Purpose in Heinz
Chapter 255: The Non-Tax Implications of the Taxation of Partnership Options
Chapter 257: No ‘Bliss’ in New Phoenix Sunrise—Tax Court Rejects and Penalizes a Tax Shelter Transaction
Chapter 258: CA-7 Sinks Penalties in One Son-of-BOSS Case, While Reg 1.752-6 Is Torpedoed Again in Another
Chapter 259: Castle Harbour III: A Taxpayer Victory as the District Court Refuses to Surrender
Chapter 261: Bad Facts Result in a Taxpayer Loss in the First SILO Case to Be Adjudicated
Chapter 262: In Klamath, the Fifth Circuit Clarifies Its Test for Economic Substance
Chapter 262A: A Tale of Two Cases: G-I Holdings and Virginia Historic Tax Credit Fund—Can They Both Be Right?
Chapter 262B: Who’s Afraid of Virginia Historic Tax Credit Fund?
Chapter 262C: IRS Misses on the Boardwalk
Chapter 262D: New Rehabilitation Credit Safe Harbor–Limiting Historic Boardwalk Hall
Chapter 262E: Hoosier Energy and the Limits of the Tax Law
Chapter 262F: New Tax Shelter Cases and Notices Put Spotlight on the Economic Substance Doctrine
Chapter 263: Avoiding Penalties with Tax Opinions After Long Term Capital
Chapter 264: New Guidance Sheds Light on Economic Substance Doctrine and Related Penalties
Chapter 265: Tax Shelters: Appropriate Tax Minimization Planning and Compliance vs. Abusive Tax Avoidance Transactions and Penalties
Chapter 265A: ‘Codification’ of the Economic Substance Doctrine—Much Ado About Nothing?
Chapter 265B: Living with (and Dying by) the Codified Economic Substance Doctrine
Chapter 265C: Tax Credit Investments and the Ossification of the Economic Substance Doctrine
Chapter 265D: Flextronics, Sundrup, and the Application of the Economic Substance Doctrine
Chapter 265E: Sham Partnerships and Equivocal Transactions
Chapter 265F: Tax Shelters and the Decline of the Rule of Law
Chapter 265G: Second Circuit Sinks Castle Harbour (Again)—Did It Sink the FISC, Too?
Chapter 265H: Legitimate and Illegitimate Tax Planning—Two Recent Cases Show the Way
Chapter 265I: Federal Circuit Upsets a LILO Deal, and Maybe the Law on Step Transactions and Substance Over Form
Chapter 265J: Reasonable Cause and Good Faith Reliance on an Advisor Help a Son-of-BOSS Taxpayer Avoid Penalties
Chapter 265K: The STARS Are Not Aligned: Courts Split in Assessing an Alleged Tax Shelter Transaction
Chapter 265L: John Hancock—The Tax Court Applies Judicial Doctrines to SILOs and LILOs
Chapter 265M: In Southgate, Economic Substance, Substance Over Form, and Penalties Are a Dangerous Mix
Chapter 265N: The Tax Court in Barnes Group Misapplies the Step Transaction Doctrine, Imposes Penalties
Chapter 265O: BNY and AIG—Using Economic Substance to Attack Transactions the Courts Do Not Like
Chapter 265P: The Economic Substance Doctrine in Federal and State Taxation
Chapter 267: Final Corporate Tax Shelter Disclosure and List Maintenance Regulations Impose Burdens on Everyone
Chapter 268: To Disclose or Not to Disclose: Tax Shelters, Penalties, and Circular 230 in 2015
Chapter 269: Final Regulations for the Tax Shelter Disclosure Regime—Making the Rules More User Friendly
Chapter 273: Reliance on Tax Opinions: The World Changes Due to Long Term Capital Holdings and the American Jobs Creation Act
Chapter 274: The World Changes: Broad Sweep of New Tax Shelter Rules in AJCA and Circular 230 Affect Everyone
Chapter 275: What Hath Congress Wrought: The Amendment to Section 6694 Will Cause Major Problems for Everyone
Chapter 276: Privileged Communications in the Context of U.S. Tax Practice
Chapter 278: In Search of a Normative Theory of Partnership Taxation for International Tax (or How We Learned to Stop Worrying and Love Subchapter K)
Chapter 280: Foreign Partnerships Cross Border Planning
Chapter 281: Playing with Blocks: Testing a Fund’s Blocker Allocations
Chapter 282: International Joint Ventures: Basic Tax Goals and Structures
Chapter 283: International Joint Ventures: Basic Tax Goals and Structures (PowerPoint slides)
Chapter 284: International Partnerships and Joint Ventures
Chapter 285: The Anti-Inversion Provisions of Internal Revenue Code Section 7874
Chapter 286: Notice 2015-54: IRS Attacks Transfers of Property to Partnership with Related Foreign Partners and Controlled Transactions Involving Partnerships
Chapter 287: American Bar Association Section of Taxation Comments on Notice 2015-54
Chapter 290: Taxation of U.S. Individual Investor in Private Fund Exiting a Non-U.S. Project
Chapter 291: The Unresolved Tax Status of Multinational Service Partnerships and Their Partners
Chapter 294: Final Regulations Apply Subpart F to a CFC’s Distributive Share of Partnership Income
Chapter 295A: “Blockers,” “Stoppers,” and the Entity Classification Rules
Chapter 296: Partnerships Change Everything: Using a Partnership in an Outbound Stock Acquisition
Chapter 297: Foreign Partnership Reporting Requirements: Regulations Under Sections 6038, 6038B and 6046A
Chapter 298: Reporting Obligations for Foreign Partnerships
Chapter 299: Living with the 2008 Final Partnership Withholding Regulations
Chapter 299A: Kissing the Blarney Stone—A Practical Guide to Structuring Partnership Agreements and Limited Liability Company Operating Agreements in Light of the Section 1446 Regulations
Chapter 300: U.S. Taxation of Foreign Partners
Chapter 301: U.S. Taxation of Foreign Partners
Chapter 302: Special Problems of Foreign Partners
Chapter 303: The Portfolio Interest Exception in the Partnership Context
Chapter 307: Check-the-Box-Planning in the International Context
Chapter 308: Check-and-Sell Transactions: Proposed Regulations Withdrawn, but Still Under Attack
Chapter 309: Dipping Our Toes in Foreign Waters: Outbound International Partnership Issues (PowerPoint slides)
Chapter 312: Application of Fiscal Transparency Principles to Treaty Limitations on the Branch Profits Tax
Chapter 313: Tax Planning with U.S. Treaties Without LOB Provisions
Chapter 314: Hybrid Entities in Cross Border Transactions: The Canadian Experience; The U.S. Response; B.E.P.S—The O.E.C.D. End Game
Chapter 315: Select U.S. Federal Income Tax Considerations in European Joint Ventures
Chapter 316: Joint Ventures in the United Kingdom
Chapter 317: Joint Ventures in the Netherlands
Chapter 318: Joint Ventures in Spain
Chapter 319: United States Government Accountability Office Report to Congressional Requesters Large Partnerships: With Growing Number of Partnerships, IRS Needs to Improve Audit Efficiency (GAO-14-732)
Chapter 319A: Getting Ready for the New Partnership Examination Rules Enacted in the Bipartisan Budget Act of 2015
Chapter 320: Unified Reporting, Audit, and Litigation Procedures for Partnerships, LLC’s and Joint Ventures
Chapter 321: The Elective Large Partnership Rules
Chapter 322: The Uncertain Boundary Between “Partner-Level” and “Partnership-Level” Defenses Under the Partnership Audit Rule
Chapter 323: Bedrosian: The Tax Court Wades into a Procedural Morass Under TEFRA
Chapter 323A: Understanding the New Partnership Audit Rules
Chapter 323B: American Institute of CPAs (AICPA) Comment Letter Proposed Legislative Revisions to the Partnership Audit Regime Enacted as part of the Bipartisan Budget Act of 2015
Chapter 324: Attorney-Client Privilege and Work-Product Doctrine in Federal Tax Matters
Chapter 325: The Criminalization of Tax Practice
  Articles Reprinted from Previous Editions
  Index to Vol. 1
  Index to Vol. 2
  Index to Vol. 3
  Index to Vol. 4
  Index to Vol. 5
  Index to Vol. 6
  Index to Vol. 7
  Index to Vol. 8
  Index to Vol. 9
  Index to Vol. 10
  Index to Vol. 11
  Index to Vol. 12
  Index to Vol. 13
  Index to Vol. 14
  Index to Vol. 15
  Index to Vol. 16

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