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Allocation and Distribution Provisions

Recorded on: Jun. 9, 2017
Running Time: 01:30:15

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Taken from the Web Program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2017 recorded June, 2017 in San Francisco.

Allocation and Distribution Provisions [01:30:15]

The operation of the Section 704(b) substantial economic effect regulations, including economic effect equivalence, and “partner’s interests in the partnership,” as well as the rules governing nonrecourse and partner nonrecourse deductions, contemporary approaches to drafting partnership allocation provisions, including the various approaches to both allocation- and distribution-driven agreements, with a focus  on how these agreements work in practice

Craig A. Gerson, Todd D. Golub

The purchase price of this segment includes the following article from the Course Handbook available online:

  • Allocation of Partnership Liabilities Under Section 752 (PowerPoint slides)
    Howard E. Abrams
  • Economic, Tax, and Drafting Considerations for Preferred Partnership Interests
    Carlene Y. Miller-Lowry, Todd D. Golub
  • Allocation and Distribution Provision (PowerPoint slides)
    Craig A. Gerson, Karen Lohnes, David S. Raab, Todd D. Golub

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  • Allocation and Distribution Provisions
    Craig A. Gerson, Todd D. Golub
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